REPORT TO CONGRESS
ON HAZARDOUS WASTE DISPOSAL

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        REPORT TO CONGRESS

    ON HAZARDOUS WASTE DISPOSAL
U.S. ENVIRONMENTAL PROTECTION AGENCY
            June 30, 1973

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2d printing
with revised references

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PREFACE
Section 212 of the Solid Waste Disposal Act (P.1. 89—272) as
amended requires that the U.S. Environmental Protection Agency (EPA)
undertake a comprehensive investigation of the storage and disposal
of hazardous wastes. This document represents EPA’s Report to the
President and the Congress sumarizing the Agency’s investigations and
reconinendatlons in response to the Congressional mandate.
The findings of this report are based on a number of contractual
efforts and analyses by Agency staff carried out since the passage of
the Resource Recovery Act of 1970.
The report is organized into a sunii ary, five major sections, and
appendices. The first section discusses the Congressional mandate
and the Agency’s response to it. Next, the public health, technologi-
cal, and economic aspects of the hazardous waste disposal problem are
reviewed. A section detailing the case for hazardous waste regulation
follows. The report concludes with a discussion of implementation
issues, and findings and reconinendations.
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CONTENTS
Page
SUMMARY AND CONCLUSIONS v
Section 1 INTRODUCTION 1
Section 2 IDENTIFICATION AND DISCUSSION OF 4
THE PROBLEM
Section 3 THE CASE FOR HAZARDOUS WASTE REGULATION 23
Section 4 ISSUES OF IMPLEMENTATION 37
Section 5 FINDINGS AND RECOMMENDATIONS 62
REFERENCES 65
APPENDICES
A. The Impact of Improper Hazardous 69
Waste Management on the Environment
B. Hazardous Waste Stream Data 78
C. Decision Model for Screening, 88
Selecting, and Ranking
Hazardous Wastes
0. Sumary of Hazardous Waste 93
Treatment and Disposal
Processes
E. Decision Map for On-Site Versus 108
Off-Si te Treatment/Disposal
F. Suninary of the Hazardous Wastes 119
National Disposal Sites Concept
G. The Proposed Hazardous Waste 143
Management Act of 1973
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SUMMARY AND CONCLUSIONS
The management of the Nation’s hazardous residues--toxic
chemical, biological, radioactive, flammable, and explosive wastes——
is generally inadequate; numerous case studies demonstrate that public
health and welfare are unnecessarily threatened by the uncontrolled
discharge of such waste materials into the environment.
o Based on surveys conducted during this program, it is
estimated that the generation of non-radioactive hazardous wastes is
taking place at the rate of approximately 10 million tons yearly.’
About 40 percent by weight of these wastes are inorganic materials,
60 percent are organics; about 90 percent of the waste occurs in liquid
or semi-liquid form.
o Hazardous waste generation is growing at a rate of 5 to 10
percent annually as a result of a number of factors: increasing pro-
duction and consumption rates, bans and cancellations of toxic sub-
stances, and energy requirements (which lead to radioactive waste
generation at higher rates).
o Hazardous waste disposal to the land is increasing as a
result of air and water pollution controls (which capture hazardous
wastes from other media and transfer them to land) and denial of
heretofore accepted methods of disposal such as ocean dumping. 2
o Current expenditures by generators for treatment and disposal
of such wastes are low relative to what is required for adequate treat-
ment/disposal. Oce n dumping and simple land disposal costs are on the
order of $3 per ton whereas environmentally adequate management could
require as much as $60 per ton if all costs are internalized.
o Federal, State, and local legislation and regulations dealing
with the treatment and disposal of non-radioactive hazardous waste are
generally spotty or nonexistent. At the Federal level, the Clean Mr
Act, the Federal Water Pollution Control Act, and the Marine Protection,
Research and Sanctuaries Act provide control authority over the
incineration, water and ocean disposal of certain hazardous wastes, but
not over the land disposal of residues. Fourteen other Federal laws
deal in a peripheral manner with the management of hazardous wastes,
and approximately 25 States have limited hazardous waste regulatory
authority.
o Given this permissive legislative climate, generators of
waste are under little or no pressure to expend resources for the
adequate management of their hazardous wastes. There are few economic
incentives (given the high costs of adequate management compared to
costs of current practice) for generators to dispose of wastes in
adequate ways.
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Technology is available to treat most hazardous waste
streams by physical, chemical, thermal and biological methods, and
for disposal of residues. Use of such treatment/disposal processes
is costly, ranging from a low of $1.40/ton for carbon sorption, $lO/
ton for neutralization/precipitation and $13.60/ton for chemical
oxidation, to $95/ton for incineration. 4 Several unit processes are
usually required for complete treatment/disposal of a given waste
stream. Transfer and adaptation of existing technology to hazardous
waste management may be necessary in some cases. Development of new
treatment and disposal methods for some wastes (e.g., arsenic trioxide
and arsenites and arsenates of lead, sodium, zinc and potassium) is
required. 5 In the absence of treatment processes, interim storage of
wastes on land is possible using methods that minimize hazard to the
public and the environment (e.g., secure storage, membrane landfills,
etc.).
A small private hazardous waste management industry has
emerged in the last decade, offering treatment/disposal services to
generators. The industry currently has capital investments of approxi-
mately $25 million and a capacity to handle about 2.5 million tons of
hazardous materials yearly, or 25 percent of capacity required nationally.
The industry’s current throughput of hazardous waste is about 24 percent
of installed capacity or 6 percent of the national total. The low
level of utilization of this industry’s services results from the
absence of regulatory and economic incentives for generators to manage
their hazardous wastes in an environmentally sound manner. This
industry could respond over time to provide needed capacity if a
national program for hazardous waste management, with strong enforcement
capabilities, were created. This industry would, of course, be subject
to regulation also.
o The chief prograninatic requirement to bring about adequate
management of hazardous wastes is the creation of demand and adequate
capacity for treatment/disposal of hazardous wastes. A national policy
on hazardous waste management should take into consideration environ-
mental protection, equitable cost distribution among generators, and
recovery of waste materials.
o A regulatory approach is best for the achievement of
hazardous waste management objectives. A regulatory approach ensures
adequate protection of public health and the environment. It will
likely result In the creation of treatment/disposal capacity by the
private sector without public funding. It will result in the mandatory
use of such facilities. Costs of management will be borne by those
who generate the hazardous wastes and their customers rather than the
public at large and thus cost distribution will be equitable. Private
sector management of the wastes in a competitive situation can lead to
an appropriate mix of source reduction, treatment, resource recovery
and land disposal.
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o A regulatory program will not directly create a prescribed
system of national disposal sites, however, due to uncertainties
inherent in the private sector response. EPA believes that the private
sector will respond to a regulatory program. However, full assurance
cannot be given that treatment/disposal facilities will be available in
a timely manner for all regions of the Nation nor that facility use
charges will be reasonable in relation to cost of services. Also,
private enterprise does not appear well suited institutionally to long
term security and surveillance of hazardous waste storage and disposal
sites.
o Based on analyses performed to date, EPA believes that no
Government actions to limit the uncertainties in private sector response
are appropriate at this time. However, if private capital flow were
very slow and adverse environmental effects were resulting from the
investment rate, indirect financial assistance in forms such as loans,
loan guarantees or Investment credits could be used to accelerate
investment. If facility location or user charge problems arose, the
Government could impose a franchise system with territorial limits and
user charge rate controls. Long term care of hazardous waste storage
and disposal facilities could be assured by mandating use of Federal or
State land for such facilities.
o EPA studies indicate that treatment/disposal of hazardous
wastes at central processing facilities is preferable to management
at each point of generation in most cases due to economies of scale,
decreased environmental risk, and increased opportunities for resource
recovery. However, other forces may deter creation of the “regional
processing facility” type of system. For example, the pending effluent
limitation guidelines now being developed under authority of the
Federal Water Pollution Control Act may force each generator to install
water treatment facilities for both hazardous and nonhazardous aqueous
waste streams. Consequently, the absolute volume of hazardous wastes
requiring further treatment at central facilities may be reduced and the
potential for economies of scale at such facilities may not be as
strong as it is currently.
o Given these uncertainties, several projections of future
events can be made. Processing capacity required nationally was
estimated assuming complete regulation, treatment and disposal of all
hazardous wastes at the earliest practicable time period. Estimates
were based on a postulated scenario in which approximately 20 regional
treatment/disposal facilities are constructed across the Nation. Of
these, 5 would be very large facilities serving major industrial areas
treating 1.3 million tons yearly each, and 15 would be medium size
facilities each treating 160,000 tons annually. An estimated 8.5 million
tons of hazardous wastes would be treated/disposed of away from the
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point of generation (off-site); 1.5 million tons would be pre-
treated by generators on-site, with 0.5 million tons of residues
transported to off-site treatment/disposal facilities for further
processing. Each regional processing facility was assumed to pro-
vide a complete range of treatment processes capable of handling all
types of hazardous wastes, and, therefore, each would be much more
costly than existing private facilities.
Capital requirements to create the system described above
are approximately $940 million. Average annual operating expenditures
(including capital recovery and operating costs) of $620 million would
be required to sustain the program. These costs are roughly estimated
to be equivalent to 1 percent of the value of shipments from industries
directly impacted. In addition, administrative expenses of about $20
million annually for Federal and State regulatory programs would be
necessary. For the reasons stated earlier, however, capacity and capital
requirements for a national hazardous waste management system may be
smaller than Indicated above, and more in line with the capacity and
capital availability of the existing hazardous waste management industry.
o In summary, the conclusions of the study are that (1) a
hazardous waste management problem exists and its magnitude is
increasing; (2) the technical means to solve the problem exist for most
hazardous waste but are costly in comparison with present practices;
(3) the legislative and economic Incentives for using available techno-
logy are not sufficient to cause environmentally adequate treatment!
disposal in most cases; (4) the most effective solution at least
direct cost to the public Is a program for the regulation of hazardous
waste treatment/disposal; (5) a private hazardous waste management
service industry exists and is capable of expanding under the stimulus
of a regulatory program; (6) due to inherent uncertainties, private
sector response cannot be definitely prescribed; (7) several alternatives
for government action are available, but, based on analyses to date, EPA
is not convinced that such actions are needed.
The Environmental Protection Agency has proposed legislation to the
Congress which is intended to fulfill the purposes of Section 212 of
the Solid Waste Disposal Act as amended, and to carry out the recom-
mendations of this report. The proposed Hazardous Waste Management Act
of 1973 would authorize a regulatory program for treatment/disposal
of EPA—designated hazardous wastes; the States would Implement the
program subject to Federal standards in most cases. All studies
performed In response to Section 212 will be completed in time to serve
as useful input to Congressional consideration of our legislative
proposal.
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Section 1
INTRODUCTION
The Congressional Mandate
In 1970, Congress perceived hazardous waste storage and disposal to
be a problem of national concern. Section 212 of the Resource Recovery
Act of 1970 (P.L. 91-512--an amendment to P.1. 89-272), enacted on
October 26, 1970, required that the U.S. Environmental Protection Agency
(EPA) prepare a comprehensive report to Congress on storage and disposal
of hazardous wastes. ihat section stated:
“The Secretary* shall submit to the Congress no later
than two yearst after the date of enactment of the
Resource Recovery Act of 1970, a comprehensive report
and plan for the creation of a system of national
disposal sites for the storage and disposal of hazardous
wastes, including radioactive, toxic chemical, biological,
and other wastes which may endanger public health or
welfare. Such report shall include: (1) a list of
materials which should be subject to disposal at any
such site; (2) current methods of disposal of such
materials; (3) recommended methods of reduction,
neutralization, recovery or disposal of such materials;
(4) an inventory of possible sites including existing
land or water disposal sites operated or licensed by
Federal agencies; (5) an estimate of the cost of
developing and maintaining sites Including considera-
tion of means for distributing the short- and long-term
costs of operating such sites among the users thereof;
and (6) such other information as may be appropriate . 0
The EPA Response
This document represents EPA’s Report to the President and the
Congress summarizing the Agency’s Investigations and recomendations
* The Secretary 0 f Health, Education and Welfare; Reorganization Plan
Number 3 of 1970 transferred authority to the Administrator, Environmental
Protection Agency.
t EPA requested and received a time extension for submission of this
report until June 30, 1973, since appropriation of funds to Implement the
Resource Recovery Act of 1970 was delayed for 8 months after enactment.
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concerning hazardous wastes in response to the Congressional mandate.
All information required by the mandate is included In the report and
its appendices. This report provides a definition of current status,
Issues and options. rt does not purport to provide a complete solution
to the hazardous waste management problem.
Section 212 requires an evaluation of a system of national disposal
sites (NDS) for the storage and disposal of hazardous wastes as a solution
to the hazardous waste problem. To evaluate the NDS concept properly, it
Is necessary to view it in the context of the total problem. On probing
the problem, EPA determined that several means of accomplishing the NDS
objective exist. To provide the Congress with maximum flexibility of
action, EPA elected to investigate and evaluate severa’ alternative
solutions.
A series of Interrelated contractor and in-house studies was under—
taken for the specific purpose of complying with Section 212 of the
Resource Recovery Act of 1970:
0 The first study, upon which subsequent fforts were based,
Quantified the hazardous waste problem.° From a thorough
Titerature survey and contacts with various trade and tech-
nical associations, government agencies, and Industry, a
list of hazardous materials was compiled, and each candidate
substance on this list was rated according to the nature
and severity of its hazardous properties. In addition,
volume and distribution data (both by geography and by
industry groups) was gathered, and current hazardous waste
handling and disposal practices were surveyed. It was
found that the magnitude of the hazardous waste problem was
larger than originally anticipated, and that current disposal
practices are generally inadequate.
o Next, a more detailed technical study on the properties of
these materials and their treatment and disposal methods was
conducted. 7 A “profile report” was written on each listed
substance sumarizing Its physical, chemical, and toxicological
properties, Its industrial uses, and the hazards associated
with proper handling and disposal methods. Each “profile
report” Incorporated a critical evaluation of currently used
and available technology for the handling, storage, transport,
neutralization, detoxification, reuse, and disposal of the
particular substance. Also, advanced methods of hazardous
waste treatment were surveyed, and research and development
needs were formulated. The study showed that treatment and
disposal technology is available for most hazardous wastes.
0 A favorable public attitude Is essential for the successful
implementation of any nationwide hazardous waste management
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program. Therefore, a third study was undertaken to determine
citizen awareness and attitudes regarding the hazardous waste
problem) and reaction to the possibility of having a treatment
and disposal facility located In the vicinity. 8 The majority
of citizens sampled were found to be in favor of regional
processing facilities for hazardous wastes since such facili-
ties would increase environmental protection and stimulate
the economy of the region.
A fourth study analyzed and compared alternative methods of
hazardous waste management. 9 It was concluded that there are
three basic approaches: (a) process hazardous wastes “on-site,”
i.e., at the plant where they are generated; (b) process
“off-site” at some regional facility (either public or private);
Cc) combine “on-site° pretreatment with “off-site” treatment
and disposal. These basic alternatives were evaluated with
respect to economics, risk, and legal and institutional issues.
The study indicated that option (b) is preferable for most
hazardous waste streams* and option (c) is preferable for
dilute aqueous toxic metal wastes.
o A fifth comprehensive study examined the feasibility of a
system national disposal sites (NDS) for hazardous
wastes.’ Potential locations for regional processing and
disposal sites were identified. Conceptual designs of
hazardous waste treatment and disposal facilities were
developed based on multi-component waste streams charac-
teristic of industry. Capital and operational costs esti-
mates were made, and funding and cost distribution mechanisms
were examined.
o Lastly, a strategy analysis was performed, based on information
from the previous studies. It was concluded that a regulatory
program is the best approach to the hazardous waste problem.
The case for hazardous waste regulation is discussed in Section 3.
Issues of implementation are evaluated in Section 4 and findings and
recooTnendations are given in Section 5. A review of the hazardous waste
disposal problem precedes these discussions.
* In this report the term “waste stream” refers to mass flow in the
engineering process sense, and not necessarily to a liquid stream.
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Section 2
IDENTIFICATION AND DISCUSSION OF THE PROBLEM
Inadequate hazardous waste management has the potential of causing
adverse public health and environmental impacts. These impacts are
directly attributable to the acute (short range or ininediate) or chronic
(long range) effects of the associated hazardous compound or combination
of compounds, and production quantities and distribution. 11 , 12 Many cases
document the inininent and long-term danger to man or his environment from
improper disposal of such hazardous wastes. For example:
o Several people in Minnesota were hospitalized in 1972
after drinking well water contaminated by an arsenic
waste buried 30 years ago on nearby agricultural land.
o Since 1953 an Iowa company has dumped several thousand
cubic yards of arsenic-bearing wastes on a site located
above an aquifer supplying a city’s water. Arsenic
content in nearby monitoring well samples has been
measured as high as 175 ppm; the U.S. Public Health
Service drinking water standards reconinend an arsenic
content less than 0.05 ppm.
o In Colorado a number of farm cattle recently died of
cyanide poisoning caused by indiscriminate disposal of
cyanide-bearing wastes at a dump site upstream.
Additional case studies citing the effects of hazardous waste
mismanagement are given in Appendix A.
Discussed in this section are: the types, forms, sources, and
quantities of hazardous waste; the current status of treatment and
disposal technology; and the economic incentives bearing on hazardous
waste treatment and disposal.
The Nature of Hazardous Wastes
The term “hazardous waste” means any waste or combination of wastes
which pose a substantial present or potential hazard to human health or
living organisms because such wastes are lethal, nondegradable,
persistent In nature, biologically magnified, or otherwise cause or tend
to cause detrimental cumulative effects. 13 General categories of
hazardous waste are toxic chemical, flaninable, radioactive, explosive
and biological. These wastes can take the form of solids, sludges,
liquids, or gases.
The sources of hazardous wastes are numerous and widely scattered
throughout the nation. Sources consist of Industry, the Federal
Government (mainly the AEC and DOD), agriculture, and various insti-
tutions such as hospitals and laboratories.
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During this study waste streams containing hazardous compounds were
identified and quantified by industrial source (see Appendix B). These
waste streams were selected by utilizing a decision model (see Appendix C) 14
which is relatively unsophisticated compared to that required for standard
setting purposes. Therefore, the hazardous compounds and waste streams
cited in this report should be considered as illustrative and not
necessarily those that should be regulated. From these data, the
total quantity of non-radioactive hazardous waste streams generated
by industrial sources in 1970 was estimated to be 10 million tons
(9 million metric tons), or approximately 10 percent of the 110 million
tons (100 pillion metric tons) of all wastes generated by industry
annual1y. 1 This quantity includes most industrial wastes generated
from contractor operated government facilities.
Approximately 70 percent of industrial hazardous wastes are generated
in the mid Atlantic, Great Lakes, and Gulf Coast areas of the United States
(see Table 2.1). About 90 percent by weight of industrial hazardous wastes
are generated in the form of liquid streams of which approximately 40 percent
are inorganic, and 60 percent are organic materials. Representative hazardous
waste substances have been cross-indexed by industrial sources in Figure 2.1.
It is important to recognize that these hazardous substances are constituents
of waste streams, and it is these waste streams which require treatment,
storage, and disposal.
Sources of radioactive wastes are: nuclear power generation and fuel
reprocessing facilities; private sources, such as medical, R&D, and
industrial laboratories; and government sources (AEC and DOD). Quantities
of radioactive wastes generated in 1970 from the first two sources have
been identified in Table 2.2. Only a limited amount of information is
available on source material, special nuclear material or by-product
materials from government operations. Such information is related to
weapons production and is therefore classified.
Disposal of uranium mill tailings represents a unique problem similar
in magnitude to the disposal of all industrial hazardous wastes. Several
Federal agencies are working on the problem at present; a satisfactory
disposal or recovery method has not yet been defined. Aside from uranium
mill tailings, the quantity of radioactive wastes associated with the
coniiiercial nuclear electric power Industry and other private sources is
estimated to be approximately 24,000 tons (22,000 metric tons) per year at
present, or less than one percent of the total hazardous wastes from all
industry.
Toxic Wastes . Practically all of the estimated 10 million tons (9 million
metric tons) of non-radioactive hazardous waste generated annually in the
United States falls into the toxic category. In the context of this report
toxicity is defined as the ability of a waste to produce injury upon contact
with or accumulation in a susceptible site In or on the body of a living
organism. Most toxic wastes belong to one or more of four categories:
(1) inorganic toxic metals, salts, acids or bases, (2) synthetic organics,
(3) flaniiiables, (4) explosives. There is considerable overlap within these
waste categories. For example, a synthetic organic waste may be flamable
and explosive, and it may also contain toxic metals. Flammable and explosive
wastes are often categorized as separate hazardous waste entities; however,
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Table 2.1
Estimated Industrial Hazardous Waste Generation by Region*
(Tons/Year)
Sludges, p Percent
Region Inorganic in Aqueous Organics in Aqueous Organics S lurrles ,Solids Total of Total
tons metric tons tons metric tons tons metric tons tons nietrIa .t ns tons metric tons
New England O0 (86,000) 17o,000 (154,000) 7OO0 (30,000) 7O0O (5,450) 30 0 (275,450) 3.1
Mid Atlantic 1,000,000 (907,200) 1,100,000 (1,000,000) 105,000 (90,600) 55,000 (50,000) 2,260,000 2,047,8O0) 22.9
East North Central 1,300,000 (1,180,000) 850,000 (770,000) 145,000 (132,000) 90,000 (81,600) 2,385,000 (2,163,600) 24.2
West North Central 65,000 (59,000) 260,000 (236,000) 49,500 (45,000) 18,500 (16,800) 393,000 (350,800) 4.0
South Atlantic 230,000 (208,500) 600,000 (545,000) 75,000 (68,000) 80,000 (72.600) 985,000 (894,100) 10.0
East South Central 90,000 (81,700) 385,000 (350,000) 44,000 (40,000) 9,500 (8,600) 528,000 (480 300) 5.4
West South Central 320,000 (290,000) 1,450,000 (1,315,000) 180,000 (163,000) 39,000 (35,400) 1,989,000 (1,803,400) 20.2
West (Pacific) 120,000 (109,000) 550,000 (500,000) 113,000 (103,000) 30,500 (27,770) 813,500 (739,770) 8.3
Mountain 125,000 (113,500) 5,000 (4,540) 50,000 (45,400) 11,500 (10,400) 191,500 (173 840) 1.9
TOTALS 3,345,000 (3,034,900) 5,370,000 (4,874,540) 794,500 (717,000) 340,000 (308,620) 9,849,500 (8,929,060) 100.0
* Refers to Bureau of Census regions, as defined in Appendix B.
P Predominantly Inorganic.
Note: Data for 1970
SOURCE: EPA Contract No. 68-01—0762

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Figure 2.1
Representati ye Hazardous Substances Wi thin Industrial Waste Streams
*
Hazardous Substances
Industry
Mining & Metallurgy
Paint & Dye
Pesticide
Electrical & Electronic
Printing & Duplicating
Electroplating &
Metal Finishing
Chemical Manufacturing
Explosives
Rubber & Plastics
Battery
Pharmaceutical
Textile
Petroleum & Coal
Pulp & Paper
Leather
x ,x x x x x x x
I I p
I I I I I I
:x:x:x:x:x: XIX’
———4—— a
1 I I I I I I
x 1 X IXIXIXI x
.a
I I I I I I I I
x , xxxx’
.1
I I I I I I I I
x x{x IxI x
. 1 I
I I I I I I I I I
I I I I I I
Ix: xxx
I I I I I I I I I
_• I
I I I I $
x x: x ‘,
J -
1 I I I I I I I I
x
————.p———.p _I 1
I I I I I I I I
: ‘ :
.J___I. -I
I I I I I I
x XIX’
.J———t
I I I I I I
X I ‘ 1 I X’ x 1 1
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I I I I I I I
I 1 I I I I I I
IA ,X X ,
————I-———. . .J___,.___p -1
I I I I I I I I
x : X : : :x:
—I .
I I I I I I I I
I I I I I 1 I I
I I I i 1 A A
.J___l. 1
I I I I I I
I I I I I I I I
Ix , I I I X a
I I I I I I I I I
I I I I I I I I
I . — . -,.—
* Including pol ’chlorlnated b-iphenyls
t E.g.: acrolein, chloropicrin , dimethyl sulfate, dinitrobenzene,
dinitrophenol, rutroaniline, and pentachlorophenol.
0
/
//
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Table 2.2
Estimate of Radioactive Waste Generated h 1970
j jor Radioactive
Waste Stream Source Form Total Annual Curies Tons/year Metric Tons/year Elements
sludge 4,400,00
solid or liquid 2,240
solid or liquid
solid or liquid
sludges, solids
or liquids
* Uranium mill tailings from extraction of uranium ores.
a,
9.0 x l0
4.0 x l0
I 1neral Extraction *
(Uranium)
Commercial Nuclear
Electric Power
Miscellaneous Private
Sources
Government Sources
All Known Sources
4,000,000
2,000
2.Ox l0
11,000-22,000
10,000-20,000
Not Available
Not Available
Not Available
4.Ox l0
4,413,240 4,012,000
Ra, Th, Pb, & P0
U,Th, Ra, Pu, Ag
Fe, H, Mn, Ni, Co,
Ru, Cs, Ce, Sr, Sb,
Pm, Eu, Am & Cm
Co, Sr, Pm, Cs, Pu,
Am, & Cm
Pu, Am & Cm
Source: EPA Contract No. 68-01-0762

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they are generally toxic and will be discussed here. Many radioactive and
some biological wastes are also toxic, but they will be discussed separately.
Toxic Metals . Ap roximately 25 percent of the metals in common usage today
are toxic metals.’ 6 The concentration and chemical form of toxic metals
determine their potential health and environmental hazards. Some metals
are essential to life at low concentrations but are toxic at higher
concentrations .l 7 l 8 AlsiA a pure metal is usually not as dangerous as a
metallic compound (salt). ‘ The largest quantities of toxic metal waste
streams are produced by the mining and metallurgy and the electroplating
and metal finishing industries. For example, arsenic-containing flue dusts
collected from the smelting of copper, lead, zinc and other arsenic-bearing
ores amount to 40,000 tons (36,200 metric tons) per year. Approximately
30,000 tons (27,200 metric tons) of chromium-bearing waste is discharged
from the metal finishing industry annually.
Synthetic Organics . Hazardous synthetic organic compounds include halogenated
hydrocarbon pesticides (such as endrin), polycholorinated biphenyls (PCB),
phenols, etc. An estimated 5,000 tons (4,540 m ric tons) of synthetic
organic pesticide wastes were produced in 1970. The Department of Defense
(DOD) currently has 850 tons (770 metric tons) of dry pesticides and 15,000
tons (13,600 metric tons) in liquid form requiring disposal. Most of the
liquid form consists of agent orange herbi de (a mixture of 2,4-D and
2,4,5-T) banned from use in South Vietnam.’’ These stocks contain significant
quantities of a teratogeriic dioxin. There are disposal requirements caused
by the increasing numbers of waste pesticide containers as well. Over 2 0
million pesticide containers of all types will be used this year alone. 2 ’
Flammables . Flammable wastes consist mainly of contaminated organic solvents,
but may include oils, pesticides, plasticizers, complex organic sludges, and
off-specification chemicals. Highly flammable wastes can pose acute handling
and chronic disposal hazards. Hazards related to disposal may exceed those
of transportation and handling if sufficient waste volumes are involved. The
nationwide quantities of flammable wastes have not been assessed as a separate
category, but are included in the totals given previously.
Explosives . Explosive wastes are mainly obsolete ordnance, manufacturing
wastes from the explosives industry, and contaminated industrial gases.
The largest amount of explosive waste is generated by the Department of
Defense (DOD). An inventory by the DOD Joint Commanders Panel on Disposal
Ashore indicates that the military has accumulated about l Q,00O tons
(136,080 metric tons) of obsolete conventional ammunition. “ The former
practice of loading obsolete munitions on ships and sinking them in the
ocean has been discontinued. Final disposal is being delayed until a
more suitable disposal method is available. A Joint Army, Navy, NASA and
Air Force (JANNAF) group is working to resolve this impasse. Most waste
materials generated by the coimiiercial explosives industry consist of
chemical wastes that are not clearly separable from wastes produced by
large industrial chemical firms (e.g., ammonia, nitric acid, sulfuric
9

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acid, some common organic chemicals, etc.). These wastes represent a
greater problem than military wastes because of uncontrolled disposal
practices. Open burning of explosives, which is widely practiced, can
result in the emission of harmful nitrogen oxides and other pollutants.
Radioactive Wastes. 24 Most radioactive wastes consist of conventional
non-radioactive materials contaminated with radionuclides. The concen-
tration of the latter can range from a few parts per billion to as high
as 50 percent of the total waste. Frequently, many radionuclides are
involved in any given waste, Radioactive wastes are customarily categorized
as low- or high-level wastes, depending upon the concentrations of radio-
nuclides. However, the long term hazard associated with each waste is not
necessarily proportional to the nominal “level” of radioactivity, but rather
to the specific toxicity and decay rate of each radionuclide. The most
significant radionuclides, from the standpoint of waste management, decay
with half-lives of months to hundreds of thousands of years. For the
purposes of this study, the term high level wastes refers to those requiring
special provisions for dissipation of heat produced by radioactive decay.
Low level waste refers to all others.
The biological hazard from radioactive wastes is primarily due to
the effects of penetrating and ionizing radiation rather than to chemical
toxicity. On a weight basis, the hazard from certain radionuclides is more
acute than the most toxic chemicals by about six orders of magnitude. The
hazard from radionuclides cannot be neutralized by chemical reaction or by
any currently practicable scheme. Thus, the only currently practical way
to “neutralize” a radionijcJide is to allow its decay. Storage of wastes
containing radionuclides under carefully controlled conditions to assure
their containment and isolation is necessary during this decay period. The
time period necessary for decay of radionuclides to levels acceptable for
release to the environment varies with each waste.
Radionuclides may be present in gaseous, liquid, or solid form.
Solid wastes p se are not normally important as potential contaminants
in the bioshpere iTh til they become airborne (usually as particulates) or
water—borne (by leaching). Consequently, environmental effects and existin
regulatory limits are based primarily on concentrations in air and water.
Biological Wastes . Biological wastes were divided into two categories for
this study: pathological hospital wastes and warfare agents. Pathological
wastes from hospitals are usually less infectious than biological warfare
agents. Both types of wastes may also be toxic. For example, toxins
produced by various strains of microorganisms may be just as hazardous as
the associated infectivity of the organism.
Approximately 170,000 tons (154,000 metric tons) of pathological
wastes are generated by hospitals annually, which is approximately 4 percen
of the total 4.2 million tons (3.7 million metric tons) of all hospital
10

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wastes generated per year. 25 ’ 26 These wastes include malignant or benign
tissues taken during autopsies, biopsies, or surgical procedures, animal
carcasses and wastes, hypodermic needles, off-specification or outdated
drugs, microbiological wastes, and bandaging materials.
Biological Warfare (BW) Agents . These are selected primarily because of
their ability: (1) to penetrate outer epithelial tissues of plants or
animals and (2) to spread rapidly. Antipersonnel agents like Bacillus
anthrax are cultured to affect a specific animal, whereas anticrop agents
like Puccinia graminis (Lx) (Rice blast) are used to inhibit growth of
specific plants. DOD representatives have advised EPA that all stockpiles
of biological warfare agents, including antipersonnel and anticrop agents,
have been destroyed.27 Due to the Administration’s policy of restricting
production of BW agents, the total quantity to be disposed of should be
small in the future.
Chemical Warfare Agents . Production of chemical warfare agents such as
ND (mustard), GB, and VX has been discontinued, but significant stockpiles
of these agents must be treated and disposed of in an environmentally
acceptable manner. The Department of the Army is in the process of
demilitarizing HD (mustard) at Rocky Mountain Arsenal in Colorado, and is
presently studying the feasibility of demilitarizing GB and VX by means of
incineration. The exact quantity of chemical agents to be incinerated is
classified, but it has been estimated that after the treatment process
there will be approximately 70,000 tons (63,600 metric tons) of residual
salts that will require proper disposal.
Factors Influencing the Growth of Hazardous Wastes .
A number of factors will increase the quantities of hazardous wastes
generated in the future and will affect their disposal requirements. Some
of these factors are production and consumption rates, legislative and
regulatory actions, energy requirements, and recycling incentives.
National production and consumption rates are increasing 4 to 6 percent
each year, while resource recovery from wastes is declining. During the
period 1948 to 1968, U.S. consumption of selected toxic metals increased
43 percent. 28 Since 1954, production of synthetic organic chemicals has
increased at an average rate of 10.5 percent per year. 29 Included in the
latter category are such materials as dyes, pigments, and pesticides. Some
of these products contain heavy metals in addition to organic constituents.
Similar data indicating production growth can be cited for most industries
which generate hazardous waste. There is a correlation between the amount
of production and waste generated. Therefore, it can be concluded that
hazardous waste generation rates will generally parallel industrial
production rates.
11

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Changing product material content also has an impact. For example,
increasing polyvinyichioride (PVC) plastics usage results in more mercury-
bearing wastes from the chlorine production industry; in the computer
industry, changeover from vacuum tube technology to integrated circuit
board technology has resulted in increased generation of acid etchant
wastes containing heavy metals.
The Nation’s projected energy requirements are driving utilities
towards construction of nuclear powered facilities. As of September 1972,
there were 28 nuclear power plants in operation, 52 were being built, and
70 more were being planned. Operation of the additional 122 nuclear power
plants will definitely increase the quantities of radioactive wastes. °
Shortages of clean burning high grade coal have initiated a trend to utilize
lower grades of coal, which contain larger amounts of arsenic and mercury;
therefore, aqueous wastes from the scrubbers and ashes from coal burning
furnaces will contain increased quantities of toxic wastes.
Enforcement of new consumer and occupational safety legislation
could result in product bans with attendant disposal requirements. More
stringent air and water effluent controls, new pesticide controls, and the
new restrictions on ocean dumping of wastes will result in larger quantities
of hazardous wastes in more concentrated form requiring disposal. As air,
water and ocean disposal options are closed off, there will be increased
pressure for improvements in production efficiency, for recovery and
recycling of hazardous substances, and for disposal of hazardous wastes on
or under the land.
Public Health and Environmental Effects
In order for an organic or inorganic hazardous compound within a waste
to affect public health and the environment it must be present in a certain
concentration and form.
Public health and environmental ef c are directly correlated with thE
concentration and duration of exposure. ‘ This has been better doc11T1ente
for acute effects resulting from high concentrations over a short period of
time than for c onic effects resulting from low concentrations over a long
period of time. 3 Most Of the work to establish chronic effects has been
done on lower animals, and extrapolating the evidence directly to man
becomes difficult because of species variations. 34
Synergistic or antagonistic interactions between hazardous compounds
and other constituents within the waste can enhance or modify the overall
effects of the particular hazardous compound. As an example, the effects
of mercury salts with trace amounts of copper will be considerably accentuat
in a suitable environment.
12

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The form of a hazardous waste is also very critical because it
determines if a toxic substance is releasable to the ambient environment.
As an example, an insoluble salt of a toxic metal bound up within a sludge
mass that is to be disposed of at a landfill does not present the same
degree of immediate threat to public health and the environment as a soluble
salt of the same metal that is unbound going to the same landfill. The
interaction between biological systems and hazardous wastes is unpredictable,
and in many cases the end product is more lethal than the original waste.
An example is the conversion of inorganic mercury by anaerobic bacteria
into methyl mercury. Furthermore, persistent toxic substances can accumulate
within tissues of mammals as do certain radioisotopes. Under these circum-
stances, substances that are persistent in the ambient environment even though
in low concentrations will be magnified in the living system. As a result,
critical concentrations may accumulate in tissues and cause detectable
physi ol ogi cal effects.
Cancers and birth defects are only a few of the recorded physiological
effects that have been correlated with the presence of hazardous compounds
in mar,. Other milder effects have also been recorded like headaches, nausea,
and indigestion. In the environment, the effects of hazardous wastes are
manifested by such events as fish kills, reduced shellfish production, or
improper egg shell synthesis. 35
This evidence points to the fact that hazardous wastes are detrimental
to public health and the environment. Therefore, the real issue is to
document the fact that present management practices for treating, storing,
or disposing of hazardous wastes do not provide the necessary reassurances
that man or the environment are being adequately protected.
Present Treatment and Disposal Technology
Treatment processes for hazardous waste streams should perform the
following functions: (1) volume reduction where required, (2) component
separation, (3) detoxification, and (4) material recovery. No single
process can perform all these functions; several different processes
linked in series are required for adequate treatment. Residues from
these processes, or all hazardous wastes if treatment is bypassed, require
ultimate. disposal.
Treatment and disposal technology is available to process most hazardous
waste streams. Table 2.3 lists the hazardous waste treatment and disposal
processes examined during the course of this study. General applicability
of these processes to types and forms of hazardous wastes is indicated.
Many of these processes have been utilized previously for managing hazardous
wastes in industry and government. Several processes have capabilities
for resource recovery. Selection of appropriate methods depends on the type,
form and volume of waste, the type of process required to achieve adequate
control, and relative economics of processes.
13

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Table 2.3 ‘
Currently Available Hazardous Waste Treatment and Disposal Processes
Process
Functions
Performed
Applicable
to
Waste
Resource
Recovery
Capability
Types
Forms
123
45
6
7
8
S
LG
A. Physical Treatment
Cal ci nation
Ion Exchange
Neutral i zation
Dxi dati on
Precipitation
Reducti on
Pyrolysis
Incineration
0. Biological Treatment
Acti vated Si udges
Aerated Lagoons
Waste Stabilization
Trickling Filters
Deep Well Injection
Detonation
Engineered Storage
Land Burial
Ocean Dun inq
Vol. Reduction
Vol. Reduc./Separ.
Detoxtfi cati on
Detoxi fi cation
Detoxi fi cation
Vol. Reduc./Separ.
Detoxi fl cation
Detoxi fl cati on
Detoxification
Detoxi fi cation
Detoxification
xx x
xx
xx
xx
xxx
x
x
x
x
x
x
xx
xx
5. Radiological
6. Biological
7. Flan.nable
8. Explosive
Waste Form:
S - Solid
I — Liquid
G - Gas
Yes
Yes
Yes
Source: EPA Contract Nos. 68-03-0089, 68-01-0762 and 68-01-0556.
Carbon Sorption
Dialysis
Electro dialysis
Evaporation
Filtration
Flocculation-Settling
Reverse Osmosis
Stri ppi ny-Aninoni a
B. Chemical Treatment
Vol.
Vol.
Vol.
Vol.
Vol.
Vol.
Vol.
Vol.
Reduc . /Separ.
Re duc . /Sep ar.
Reduc. fSepar.
Reduc./Separ.
Reduc. /Sèpar.
Reduc. /Separ.
Reduc. /Separ.
Reduc./Separ.
x
xxx
xxxx
xxxx
xx
x
xxxxx
xxxxx
xx
x
x
x
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
C. Thermal Treatment
x
x
x
x
x
x
Vol. Reduc./Detox.
Detox . /Di sposal
xx
x
x
x
xx
x
x
x
x
x
x
x
x
x
xx x
xx x
x
x
x
x
x
xx x
x x x
xx
.x x x
xx x
x xxx
Ponds
x
x
x
x
x
x
x
E. Disposal/Storag
x
x
x
x
x
Disposal
Disposal
Storage
Disposal
Disposal
xxx
Yes
Yes
No
No
No
No
No
No
Yes
No
No
xx
xx
x •x
x
x
x
x
x
x
x
Waste Type:
1. Inorganic Chemical w/o Heavy Metals
2. Inorganic chemical w/Heavy Metals
3. Organic Chemical w/o Heavy Metals
4. Organic Chemical w/Heavy Metals
14’

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Several treatment processes perform more than one function, or are
applicable to more than one type or form of waste. For example, evaporat-fc i
provides both volume reduction and component separation for inorganic liquids
Carbon sorption and filtration provide component separation for both liquids
and gases, and are applicable to a wide range of heterogeneous waste stre nis.
Both carbon sorption and evaporation are capable of large throughput rates.
Neutralization, re gc ,on and precipitation are effective for separation of
most heavy metals.
Certain weaknesses are inherent in some treatment processes. For
example, the five biological treatment processes are inefficient when waste
streams are highly variable in composition and concentration, or when solutions
contain more than 1—5 percent salts. 38 Furthermore, biological treatment
processes require larger land areas for facilities than the other physical
or chemical processes. The efficiency of removal of hazardous liquids and
gases from waste streams by carbon sorption is strongly dependent on pH.
Similarly, the four dissolved solids removal processes (ion exchange,
reverse osmosis, dialysis, and electrodialysis) are all subject to operational
problems when utilized for treating heterogeneous brines. 39
Radioactive emissions and effluents from production or reprocessing
facilities are routinely controlled by a variety of treatment methods.
High efficiency filters are used to remove radioactive particulates from
gaseous effluents; caustic scrubbers of charcoal absorbers are used to
remove radioactive gases. Liquid effluents containing small quantities
of soluble or insoluble radioactive constituents are usually treated with
conventional water treatment techniques suck as ion exchange, settling,
precipitation, filtration, and evaporation. 0
Commonly used disposal processes for hazardous wastes include land
burial, deep well injection, and ocean dumping. Detonation and open
burning are sometimes used for disposal of explosives. Incineration is
used for disposal of some organic chemicals, biologicals, and flammables.
All disposal processes have potential for adverse public health and
environmental effects if used unwisely or without appropriate controls.
Land disposal sometimes consists of indiscriminate dumping on the
land with attendant public health problems from animal vectors, water
pollution from surface water run off and leaching to ground waters, and
air pollution from open burning, wind blown particulates and gas venting.
Sanitary landfills are much preferable to dumps in that daily earth
cover minimizes vector problems, open burning and particulate transport.
Unless specially designed, however, sanitary landfills still have potential
for surface and ground water pollution and air pollution from gas venting.
Deep well injection of liquid and semi-liquid wastes can pollute ground
waters unless great care is taken in site selection and construction and
operation of such wells. EPA policy opposes deep well injection unless all
15

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other alternatives have been found to be less satisfactory in tetmis of
environmental protection, and unless extensive hydraulic and geologic
studies are made to ensure that ground water pollution will be minimized.
Environmental problems associated with ocean dumping have long been
recognized. The Congress recently passed legislation to control ocean
dumping of wastes (see Section 3).
Incineration, open burning, and detonation all can result in air
pollution unless adequate controls are employed. The residues from
incineration, and from associated pollution control devices, may require
special care in disposal.
Selection of appropriate treatment and disposal methods for a given
waste is a complex process. It is simplistic to assume that a treatment
and disposal process is applicable to all wastes of a given category. For
example, available treatment and disposal processes for three types of
heavy metal hazardous wastes are illustrated in Figure 2.2. It can be
seen that significant differences exist.
Transfer and adaptation of existing technology to hazardous waste
management may be necessary in some cases. Some hazardous waste streams
(e.g., those containing arsenites and arsenates of lead, sodium, zinc
and potassium, and arsenic trioxide) cannot be treated or disposed of
adequately with existing technology. 41 Secured storage is available until
the appropriate treatment/disposal technology is developed.
Synopses of treatment and disposal processes are given in Appendix D.
Public Use of Existing Technology . The Atomic Energy Commission and the
Department of Defense presently utilize almost all the processes identified
in Table 2.3 for management of hazardous wastes. High level radioactive
treatment and storage sites operated by AEC are located at Hanford, Washingi
Savannah River, South Carolina; and the National Reactor Testing Station in
Idaho. Similar DOD operated non-radioactive hazardous waste treatment, stoi
and disposal sites are located at a great number of arsenals, depots, and
amunition plants throughout the country.
Private Use of Existing Technolqg y . Some large manufacturers, notably in
the chemical industry, have established in-house hazardous waste processing
facilities which utilize some of the treatment and disposal processes
listed in Table 2.3. EPA-held data on such in-house operations are sparse.
Based on available ocean and land disposal data it is estimated, however,
that only a small percentage of the hazardous wastes generated by industry
receive treatment and are disposed of at in-house facilities.
The Hazardous Waste Processing Industry . In recognition of this situation
several private companies have built facilities to treat, dispose, and
recycle many hazardous wastes. These companies sell waste processing
16

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FIgure 2.2
Examples of tnterrelationsMp Between Hazardous Wastes and Treatment/ lsposal Processes
A. Concentrated Heavy Metals
Hexavalent ( rcxni r — i Heavy Metal - ———---- Heavy Metal Sl 2ige Disposal
L du i J Po1 mer Encapsulation and Burial
Ca ut , Arsenic Mercuxy— Heavy Metal Heavy Metal Sluc e Disposal
Sulfide Precipitation [ Ceterit_Encapsulation and Burial
B. Heavy Metals with Organics
Heavy Metal rI Heavy Metal Sluóe Disposal
Arsenic and Organic Sulfide Precipitation J [ Tent Encapsulation and Burial
(Dilute Hydrocarbon)
+ Incineration of
Dilute Hydrocarbon
_____ neration of Dilute }Ialoqenated
- - ,,,.. — I roca±on Sen i

4 T
[ ctivated onl generat1
Sonroe: EPA Contract No. 68-01-0556

-------
services to industries in their area, generally within a 500 mile (805
kilometer) radius. However, largely because of lack of demand for services,
these regional waste processing plants still are few in number (about
ten nationwide) and operate at about 25 percent of available capacity.
The total processing capacity of all facilities is approximately
2.5 million tons (2.3 million metric tons) per year. Operating at full
capacity, these private processing firms presently could handle about
25 percent of the total nationwide non-radioactive hazardous wastes. None
of these facilities provide a complete range of treatment and disposal
processes capable of handling all types of hazardous wastes. Table 2.4
presents a suninary of information available on these firms.
As stated earlier, nuclear weapons production facilities, coninercial
nuclear power reactors and private sources generate a substantial quantity
of high- and low-level radioactive wastes. High level wastes are
controlled by the AEC. Management of low level wastes by private companies
at AEC or cooperative State sites is a highly specialized business with
limited markets. As a result there are only two companies engaged in
handling and disposing of low level radioactive wastes. The quantities of
radioactive wastes are expected to increase exponentially starting around
1980, and as a result the number of nuclear waste disposal companies
should also increase.
Economic Incentives
The costs associated with proper hazardous waste treatment and disposa
are fixed capital-intensive and vary widely, depending on the particular
treatment process that is required. Table 2.5 presents typical capital
and operating costs for a number of selected processes that are applicable
to medium-size regional industrial waste treatment and disposal facilities.
These examples illustrate that environmentally adequate technology is
expensive. Moreover, to arrive at the actual costs associated with proper
treatment of hazardous wastes, a combination of several treatment processes
is usually required.
The comparative economics of proper hazardous waste management versus
presently used environmentally inadequate practices, such as disposal in
dumps or in the ocean, are illustrated in Figure 2.3. This figure also
depicts the economies of scale that can be attained by use of large waste
processing facilities. The cost data used in support of this figure were
based on typical treatment and disposal facilities capable of handling
aqueous toxic wastes.
Figure 2.3 indicates that adequate treatment and disposal of hazardous
wastes costs 10 to 40 times more than the environmentally offensive alter-
natives. With these kinds of economic differentials, and in the general
absence of pressures to do otherwise, one realizes why the more environ-
mentally acceptable methods are seldom utilized. Available technology
cannot compete economically with the cheaper disposal alternatives. Clean
18

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Table 2.4
Summary of Information
On Privately Owned Regional Hazardous Waste Processing Plants*
Nunber of Regional plants
Estimated available capacity
Estimated utilization of
available capacity
Available capacity as percent of
required nationwide capacity
Regional distribution
Total Capital investment
Resource Recovery
Approximately 10
2,500,000 tons/year
(2,272,000 metric tons/year)
25 percent
25 percent
Mostly in North Central,
Mid-Atlantic and Gulf Coast Regions
$25 million
Limited at present mostly to
solvents and metallic salts
* This table does not consider very small firms with limited
facilities (e.g., those plants that consist solely of an
incinerator).
19

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Table 2.5
Costs of Representative Hazardous Waste Treatment Processes
Process Capacit y Capital Costs 0 eratln Costs
( 1,000 gal ./dayl ( 1,000 liters/day) ( $1,000) ( $11,000 ga . 000 liters)
1. ChemIcal Oxidation 25 94.8 400 68 18
of Cyanide Wastes
2. Chemical Reduction 42 159 340 29 7.65
of Chromium Wastes
3. Neutralization - 120 452 3,000 50 13.20
Precipitation
4. Liquid-SolIds 120 452 9,000 40 10.60
Separation
5. Carbon Sorption 120 452 910 7 1.85
0
6. Evaporation 120 452 510 10 2.64
7. Incineration 74 tons/day 67 metric tons/day 4,900 95($/ton) 105($/metric ton)
NOTE:
1. Capital costs Include land, buildings, and complete processing and auxiliary facilities.
2. Operating costs Include neutralization chemicals, labor, utilities, maintenance, amortization charges (7 percent Interest), Insurance,
taxes, and administrative expenses.
3. Data corresponds to a typical medium size treatment and disposal facility capable 0 f processing approximately 150 thousand
tons (136 thousand metric tons) per year or 600 tons (545 metric tons) per day.
SOURCE: EPA Contract no. 68-01-0762

-------
Figure 2.3
a,
4- I
• 1
0
0
0
e0
0
0
I n
In
0
r’
C
U,
U,
U
0
0
400 ( 106.00 )
300 ( 79.40) —
200 ( 52.80 )
100 (25.40) —
50 (13.20)_—
25 (6.60)_
15 (3.96)
5 (1.32).
Cost Comparison of Proper vs. Improper Hazardous Waste Management Practice6
C
Z5 120 200
(94.6) (454) (758)
Waste Volume, 1,000 gal ./day (1,000 liters/day)
Ar Environmentally adequate treatment and disposal
‘8= Land disposal
C= Ocean disposal
1 ,000
(3,785)
A
I,
Note: For aqueous wastes
Includes capital write-off but not transportation costs from the generator to nearest treatment or disposal facility.
Source: EPA Contract No. 68-01-0762 & 68-O3- fl089

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there are substantial economic incentives for industry not to use adequat
hazardous waste treatment and disposal methods.
Should a generator elect to process his hazardous wastes in an
environmentally acceptable manner, a basic decision must be made whether
the particular waste stream should be processed on-site or off-site at
some regional treatment facility, such as existing commercial waste proce!
plants. The cost analysis of this problem, as it applies to a number of
coniirnnly occurring industrial waste streams, was conducted by means of a
mathematical model that produced “economic decision maps.”42 Typical exar
are attached in Appendix E. An analysis of the decision maps indicates
that cost factors generally favor off-site treatment and disposal of indu
hazardous wastes with the exception of dilute aqueous toxic metal streams.
Other factors, such as the impact of pending water effluent standards and
transportation problems, may alter this judgment.
S urn a ry
EPA ’s findings relative to the current handling of hazardous wastes
can be sunned up as follows:
1. Current treatment and disposal practices are inadequate and
cause unnecessary hazards to all life forms.
2. Techniques for safe and environmentally sound treatment and
disposal of most hazardous wastes have been developed. Adaptati
and transfer of existing technology, and development of new
methods, is required in some cases. It is possible to retain
hazardous wastes for which treatment/disposal methods are unavai
able in long-term storage until their chemical conversion to
harmless compounds or their reuse in industrial practice becomes
feasible.
3. There are substantial economic incentives for industry not
to use environmentally adequate treatment and disposal methods.
Such methods are substantially more expensive than current
inadequate practices, and in a climate of permissive legislation
or total absence of legislation, competitive economic forces
result in least-cost disposal regardless of the environmental
consequences.
4. A small industry has emerged to treat and dispose of hazardous
and other industrial wastes. This industry is not currently
operating at capacity because it services are being utilized
only by a few clients that are concerned about the environment,
or have no cheaper disposal alternatives, or sometimes find
themselves forced to use such services because of environmental
regulations. This industry, however, has the capability to
expand to meet demands engendered by future Federal or State
actions.
It is evident that a need exists for bringing about environmentally
acceptable and safe treatment and disposal of hazardous wastes. The next
section will discuss the need for a regulatory program in order to achieve
this goal.
22

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Section 3
THE CASE FOR HAZARDOUS WASTE REGULATIONS
The previous section has shown the potential for public health and
environmental damages from mismanagement of hazardous wastes and the
lack of economic incentives for proper management. There is a strong
precedent for Federal regulation when health damage is at issue. Regu-
lation is used because the other conceptual alternative, massive economic
incentives, does not ensure compliance. Some forms of regulation,
however, may embody certain types of economic incentives.
Federal and State statutes have attempted to regulate and control
various parts of the problem, but there has never been an attempt to
regulate hazardous waste management in a comprehensive manner.
The following discusses legislative precedents regarding hazardous
wastes and illustrates a legislative gap in the regulation of land
disposal of hazardous wastes.
Existing Authorities for Hazardous Waste Management
A large body of Federal and State law exists today which exerts a
significant but peripheral impact on the land disposal of hazardous
waste. The following discussion reviews existing laws and assesses
their impact on the treatment, storage, transportation, handling, and
disposal of hazardous wastes.
Federal Control Statutes . Thirteen Federal statutes have varying degrees
of direct ii ipact on the management of hazardous wastes. Four additional
Federal statutes are either indirectly or potentially applicable to
hazardous wastes. The Clean Air Act, as amended, and the new Federal
Water Pollution Control Act will be discussed in some detail later in
this section. The other statutes and their impact on the treatment,
storage, transportation, and handling of hazardous wastes may be sum-
marized as follows:
1. The Resource Recovery Act of l97O. Section 212 of the Resource
Recovery Act directs the Administrator Of EPA to study the
teasibility of a system of national disposal sites for hazard-
ous wastes. The Act authorizes no regulatory activities,
however.
2. The Atomic Energy Act of 1954, as amended. 44 This statute
authorizes the Atomic Energy Co ission to manage radioactive
wastes generated in fission reactions both by the AEC and
private industry. High level radioactive wastes from weapons
and reactor programs are controlled directly by the AEC at
23

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its facilities; commercially generated low level radioactive
wastes are generally disposed of at facilities licensed and
controlled by the States. Naturally occurring materials, such
as uranium mill tailings and radium, and radioisotopes produced
by cyclotrons are not subject to regulation under the Act.
There is room for improvement at the radioactive waste storage
and disposal facilities, but by comparison with other hazardous
wastes, high level radioactive waste management is well regu-
lated.
3-7. The Department of Transportation is responsible for adminis-
tering five statutes which affect the transport of hazardous
wastes. The oldest of these, the Transportation of Explosives
Act 4 5 prohibits the knowing unregulated transport of explosives,
i ioactive materials, etiologic (disease-causing) agents,
and other dangerous articles in interstate commerce unless
the public interest requires expedited movement or such trans-
port involves 1 ’no appreciable danger to persons or property.”
Supplementing this law is the Hazardous Materials Transporta-
tion Act of 1970,46 a non-regulatory statute whi h autho !zes
t1 è Secretary of DOT to evaluate hazards associated with
hazardous materials transport, establish a central accident
reporting system, and recommend improved hazardous materials
transport controls. The Safety Regulation of Civil Aeronautics
A t 4 7 authorizes the Federal Aviation Administration to establish
iTI transportation standards “necessary to provide adequately
for national securi and safety in air commerce.” The
Hazardous Cargo Act’ places regulatory controls on the water
transport of explosives or dangerous substances, authorizing
the U.S. Coast Guard to publish regulations on packing, marking,
labeling, containerization, and certification R such substances.
The Federal Hazardous Substances Labeling Act 4 ’ authorizes the
DOT Secretary to identify hazardous substances and prohibits
the transport of such substances if their containers have been
misbranded or the labels removed. The Act authorizes the
seizure of misbranded hazardous substances and requires the
courts to direct the ultimate disposition of such seized
substances.
8. The Federal Environmental Pesticide Control Act of 197250
requires tne Administrator or U A to establish procedures
and regulations for the disposal or storage of packages,
containers, and excess amounts of pesticides. EPA is also
required to “accept at convenient locations for safe disposal”
those pesticides whose registration is suspended to prevent
an Inininent hazard and later canceled, if the pesticide owner
so requests. 51
24

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9. The Marine Protection, Research and Sanctuaries Act of
197252 prohibits the transport from the United States for
the purpose of ocean dumping any radiological, chemical
or biological warfare agents, high level radioactive wastes,
or (except as authorized by Federal permit) any other
material. In granting permits for ocean dumping, the EPA
Administrator must consider “appropriate locations and
methods of disposal or recycling, including landbased alter-
natives, and the probable impact of [ such use] upon consid-
erations affecting the public interest.” 53
10—11. The Clean Air Act 54 and the Federal Water Pollution Control
Act, 55 examined In detail later in this section, provide
extensive control authority over the incineration and water
disposal of certain hazardous wastes.
12. The Poison Packaging Prevention Act 56 authorizes the Secretary
oF F{EW to establish special packaging standards for hazardous
household substances whenever it can be shown that serious
personal injury or illness to children can result from handling,
using or ingesting such substances. Hazardous household
substances already identified in regulations include oven
cleaners, cigarette and charcoal lighter fluids, liquids
containing turpentine and methyl alcohol, and economic
poisons (pesticides).
13. The Food, Drug and Cosmetic Act 57 prohibits the adulteration
and misbranding of certain consumer items and requires the
disposal by destruction or sale of any Items seized under
the Act.
14. The first of the Federal statutes which have a general,
nonregulatory impact on the management of hazardous wast
is the National Environmental Policy Act of 1969 (NEPA).
Sec. 1OT(b) of NEPA requires the Federal Government to “use
all practicable means*I to attain the widest range of beneficial
uses without degrading the environment or risking health or
safety. In order to ensure that the environmental policies
expressed in Sec. 101 are effectively carried out, Sec. 102(2)
(C) requires all agencies of the Federal Government to prepare
detailed environmental impact statements for all “major
Federal actions significantly affecting the quality of the
human environment.” All Federal hazardous waste management
activities thus clearly fall within NEPA’s ambit.
15. The Armed Forces Appropriation Authorization Acts of 1969 and
l970 prohibit the use of Federal funds for the transportatfon,
o ii air testing, or disposal of any lethal chemical or
biological warfare agent in the United States except under
certain conditions requiring prior determination of the effect
on national security, hazards to public health and safety, and
practicability of detoxification prior to disposal.
25

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16. The Coastal Zone Management Act of 1972,60 in declaring it a
natTöii T policy to preserve and protect the resources of the
Nation’s coastal zone, recognizes waste disposal as a “competing
demand” on coastal zone lands which has caused “serious
environmental losses.” Because applicants for Federal coastal
zone management grants must define “permissible land and water
uses within the coastal zone,” an applicant’s failure to
regulate hazardous waste disposal within such area so that it
qualifies as a “permissible use” can serve as a basis for
denying program funds under the Act.
17. The Occupational Safe y and Health Act of 197061 authorizes the
Secretary of Labor to set mandatory standards to protect the
occupational safety and health of all employers and employees
of businesses engaged in interstate comerce. Sec. 6(b)(5)
deals specifically with toxic materials and other harmful
agents, requiring the Secretary to “set the standard which
most adequately assures. . . that no employee will suffer
material impairment of health or financial capacity” from
regular exposure of such hazards. Employees of hazardous
waste generators, and treatment and/or disposal facilities,
engaged in interstate commerce thus are clearly entitled to
the Act’s protection. It should be noted that standards
issued under the Act can directly impact some phases of
hazardous waste management. For example, the OSHA-enforced
asbestos regulation requires that certain wastes be packaged
for disposal.
State Control Statutes . At least twenty-five jurisdictions have enacted
legislation or published regulations which control hazardous waste
management activities to some degree. The most effective of these
regulatory controls are currently placed on low level radioactive wastes,
the Atomic Energy Commission having contracted with a growing number of
States for low level radioactive waste disposal. Non-radioactive
hazardous wastes, however, are essentially unregulated in practice, for
none of the twenty-five jurisdictions has fully implemented its control
legislation. The major reason for this failure is the negative approach--
broadly-worded blanket prohibitions--utilized by virtually all of these
States.
Legislative strategies which rely on blanket prohibitions rather
than comprehensive management controls are difficult or impossible to
administer In any meaningful, systematic fashion. In addition, many of
these States enact control statutes without providing for acceptable
treatment or disposal facilities. A recent survey 62 of sixteen of the
twenty—five “control” States reveals for example, that less than half
of them have treatment/disposal facilities located within their bounda-
ries (see Figure 3.1). By failing to specify acceptable alternatives
to prohibited activities, such States encourage hazardous waste
generators to ignore the law altogether or to select and employ divergent
disposal alternatives unknown to the State control authorities which may
be more environmentally harmful than the prohibited activity.
26

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Figure 3.1
Alabama
California
Colorado
Illinois
Kansas
Maine
Michigan
Nevada
New Jersey
New York
Oregon
South Carolina
Texas
Vermont
Virginia
Washington
Summary of State Legislation Survey
Alabama
California
Colorado
Illinois
Kansas
Maine
Michigan
Nevada
New Jersey
New York
Oregon
South Carolina
Texas
Vermont
Virginia
Washington
Disposal
Explosives Regulations for Presence of
Regulations on Transportation Handling Hazardous Existing Facilities
Transportation Processing_Storag DOT Regulations Other(a) Materials Radioactive Hazardous
——
— — —— ——
Yes
——
Yes
Yes
No
No
Yes No Yes
Yes
Yes
Yes
——
YQB
No
No No No
Yes
No
No
No
No
——
Yes — — ——
Yes
Yes
——
Yes
No
Yes
Yea Yes Yes
Yes
Yes
——
Yes
——
Yes
Yea —— ——
Yes
—-
Yes
No
No
Yes
Yes —— ——
No
Yes
Yes
No
Yea
Yes
No No Yes
Yes
No
No
No
No
Yes
Yes Yes Yes
Yes
——
0ev
Ye S
Yes
Yes
Yea Yes Yes
Yes
——
Yes
Yes
Yes
Yes
Yes No Yes
Yes
No
No
No
No
No
Yea No No
Yes
Yes
——
Yes
0ev
—
—— —— ——
Yes
Yes
——
Yes
Yes
Yes
Yea Yes Yes
Yes
—-
0ev
No
No
Yes
Yes Yes Yes
Yes
—
0ev
No
0ev
Yes
Yes No Yes
Yes
No
No
Yes
Yes
(a) Includeu Hauling Permit., Vehicle Registration., Material Registrations, Hills of Lading, Placard Attachaset,
and Vehicle Standards.
(b) Include. Pesticide., Toxic Substances, and other Chemical..
Solid Waste
R4n rf1,,u M P . ,vl. .1
Pesticides
Disposal
Regulations
Licensing of
Disposal Sites
Regulations
on
Regulations
on
Disposal
Transportation
Processing
Storage
Disposal
Transportation
Processing
Storage
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
Dev
Yes
Yes
Yes
Yes
Yea
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Ye
Yea
Yes
Yes
Dev
No
Yes
Yes
Yes
Yes
Yes
No
No
No
Yea
Yes
Yes
Yes
Yes
Yea
Yes
Yes
Yea
Yes
No
No
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
Yes
Yes
Yea
Yes
Yes
Yes
Yes
No
No
No
Yes
Yes
Yes
No
No
No
Yes
Yes
No
Yes
Yes
Yea
Yes
No
No
Yea
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
No
——
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Ye
No
No
No
Yes
No
Yes
Yes
Yes
Yes
Yes
No
No
No
Yes
Yes
Ye8
No
No
No
Yes
No
No
No
Source; EPA Contract No. 68—01—0762

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Sun ary : With the exception of radioactive waste disposal, which appears
to be the subject of adequate Federal and State regulation, land-based
hazardous waste treatment, storage and disposal activities are essen-
tially unregulated by Federal and State laws. Because this legislative
gap allows uncontrolled use of the land for hazardous waste disposal,
there has been little incentive for the use of proper hazardous waste
treatment and disposal technology to date. Until nationwide controls
are established, the pressure on the land as a receptor for hazardous
wastes can be expected to increase as the major hazardous waste disposal
controls of the Clean Air Act, the Federal Water Pollution Control Act
and the new Federal ocean dumping statute are tightened. The latter
statute’s mandate to the EPA Administrator to consider land-based disposal
alternatives when granting ocean dumping permits seems certain to provide
opponents of the practice of dumping toxic wastes into the ocean with a
new and powerful legal tool. Depending on the courts’ interpretation of
this statute, the Marine Protection, Research and Sanctuaries Act of 1972
could add significantly to the pressure on the land as the last disposal
medium for hazardous wastes.
The first two of these three statutes are analyzed in the discussion
which follows.
Precedents for Hazardous Waste Regulation: The Clean Air Act and the
Fe dera1 Water Pollution Control Act
Both the Clean Air Act 63 and the Federal Water Pollution Control
Act& 4 include provisions which address the problem of hazardous waste
management directly. The former statute authorizes the control of
hazardous air pollutants and the latter controls the discharge of
hazardous pollutants into the Nation’s waters.
Control Philosophy . The Clean Air Act best exemplifies a control
strategy designed to protect the public health and welfare by placing
the burden of standards compliance on the air polluter. As with most
environmental control statutes, the costs of compliance are interna-
lized by the polluter and ultimately passed on to the consumer,
indirectly in the form of tax benefits to the polluting Industries, 65
or directly in the form of higher prices for goods and services. In
the past, Clean Air Act standards have been based almost exclusively
on health effects. As a result of adverse court decisions on ambient
air quality standards, however, EPA has expanded its efforts to con-
sider, in addition to health and welfare factors (1) beneficIal and
adverse environmental effects, (2) social, economic, and other perti-
nent factors, and (3) be a 1onale for selecting the standard from
the available options.00 & ’ 0
The Federal Water Pollution Control Act Amendments of 1972
generally exemplify a control strategy based on factors in addition
to human health and welfare. Typical of the FWPCA’s new regulatory
28

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provisions are those keyed to “best practicable” control technology
and “best available technology economically achievable,” determina-
tions which are to be made by EPA from studies of the age, size and
unit processes of the point sources involved and the cost of apply-
ing effluent controls.
The Clean Mr Act . Sec. 112 of the Clean Air Act authorizes the
Administrator of EPA to set standards for hazardous air pollutants
at any level “which in his judgment provides an ample margin of safety
to protect the public health.”b9 Hazardous air pollutants are defined
as those which “may cause, or contribute to an increase in mortality
or an increase in serious irreversible or incapacitating reversible,
illness” (Sec. 112(a)(l)). Asbestos, beryllium and mercury are
three hazardous pollutants for which emission limits under Sec. 112
have been promulgated.
The Federal Water Pollution Control Act . The FWPCA contains a number
of provisions which impact directly on hazardous pollutant-bearing
wastes. Section 502(13) defines “toxic pollutant” as “those
pollutants. . . which. . . after discharge and upon exposure, ingestion,
inhalation or assimilation into any organism. . . will cause death,
disease, behavioral abnormalities, cancer, genetic mutations, physio-
logical malfunctions. . . or physical deformations on such organisms
or their offspring.” Section 115 directs EPA to locate and contract
for “the removal and appropriate disposal of (in-place toxic pollutant)
materials from critical port and harbor areas.” The potential for
increased pressure for land disposal of such toxic pollutants is
evident.
Title III of the FWPCA contains four provisions authorizing control
over toxic pollutants discharged into water from point sources . The
importance of the FWPCA’s distinction between point and nonpoint
sources cannot be overemphasized from a hazardous waste management
viewpoint, for discharges from point sources only are subject to the
Act’s regulatory controls.* Because the Act defines “point source”
as “any discernible, confined and discrete conveyance,” and offers as
examples such things as pipes, ditches, tunnels, etc., 70 Congress
seems not to have intended that land disposal facilities are to be
Includ Twithin the point source definition. In fact the opposite
appears to be true, for Sec. 304(e) of the Act requires EPA to
publish nonregulatory “processes, procedures, and methods to control
pollution resulting from. . the disposal of pollutants in wells or
In subsurface e c yations ” 1 (emphasis supplied).
*Sec. 301(a) established FWPCA’s broad prohibitions against the
“discharge of any pollutant.” Sec. 502(12) defines “discharge of
pollutants” as “...any addition of any pollutant to navigable waters
from any point source... ” (emphasis supplied).
2g

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Since the types of pollutant discharges normally associated with
improperly managed hazardous waste disposal facilities are runoff into
navigable waters and migration Into ground water supplies, it seems
safe to conclude that, unless a disposal facility discharges toxic
pollutants into a waterway through a “discernible, discrete conveyance”
such as an outfall pipe, it will be exempt from the Act’s proscriptions.
Hazardous waste treatment facilities, however, should not escape
the Act’s reach. Any toxic wastes produced by such facilities and not
treated on-site must be stored and/or eventually transported in some
manner, and any container or confined means of conveyance for such
waste, by definition in Sec. 502(13) of the Act, qualifies as a potential
“point source” of water pollution discharge.
The first of Title III’s proscriptions against toxic pollutant
discharges may be found in Sec. 301(f), which prohibits the “discharge
of any radiological, chemical, or biological warfare agent, or high
level radioactive waste into the navigable waters. 1 ’ The other statutory
authorities which impact on the disposal of these wastes were discussed
above.
Sec. 306 is the second reference to hazardous wastes. It requires
EPA to publish national standards of performance for new point source
categories reflecting “the greatest degree 0 f effluent reduction
achievable..., including where practicable, a standard permitting no
discharge of pollutants.” 72 The Act singles out such new source
categories as the organic and inorganic chemicals industries, well
known generators of toxic wastes. These standards, which must take
into account the cost of standards’ achievement and “any non-water
quality environmental impact and energy requirements,”* must be pub-
lished not later than January, 1974. Hazardous waste generators and
treatment facilities which otherwise qualify as “new” clearly are
comprehended in Sec. 306(a)(3), which defines new sources as “any
building, structure, facility, or installation from which there Is
or may be the discharge of pollutants.” This adds to the general
qualification of such facilities as point sources, discussed above.
The third FWPCA provision affecting toxic pollutants is Sec. 307
which requires EPA to identify and publish effluent standards for a
list of toxic pollutants or combinations of such pollutants. Standards
are to be set “at that level which the Administrator determines pro-
vides an ample margin of safety,” nd are to take effect not later
than one year after promulgatlon. 7 Even though Congress’ standard-
setting process mandate to EPA under this section was limited to
*Sec. 306(b)(1)(B). The FWPCA’s legislative history, however,
makes It clear that individual new sources, rather than EPA, will
determine which technologies will be used to achieve Sec. 306(b)’s
performance standards. Conference Report No. 92-1465, FWPCA
Amendments of 1972, 92nd Congress Sess. (Sept. 28, 1972, at p. 128).
30

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consideration of toxicity data alorle,* as previously discussed other
factors likely will be considered to produce judicially enforceable
standards, given recent air pollution-related court decisions.1
Sec. 311 is designed to protect the navigable waters and adjoining
shorelines of the United States and the waters of the contiguous zone
from “hazardous substance” discharges. EPA must designate as hazardous
substances those elements and compounds “which, when discharged in any
quantity,... present an iminent and substantial danger to the public
health and substantial danger to the public welfare, including but not
limited to fish, shellfish, wildlife, shorelines, and beaches. TM
Designed primarily to control spills from vessels and onshore or off-
shore facilities, Sec. 311 requires violators to pay a fixed cost for
each hazardous substance unit unlawfully discharged, with the President
alone authorized to permit certain o these discharges when he has
determined them “not to be harmful.” 5 Coastal zone-area hazardous
waste generation and treatment facilities thus would clearly be subject
to Sec. 311 controls and penalties.
*
Sec. 307(a)(2) requires the Administrator of EPA to publish
proposed toxic effluent standards (or prohibitions) which shall take
Into account (1) the toxicity of the pollutant, (2) its persistence,
(3) degradability, (4) the usual or potential presence of the affected
organism in any waters, (5) the importance of the affected organisms,
and (6) the nature and extent of the effect of the toxic pollutant on
such organisms...” No other considerations are mentioned in Sec. 307
or its legislative history.
tSee e.g., Kennecott Copper v. EPA , U.S. App. D.C. F. 2d_, 3 ERC
1682 (Feb. 8, 1972) (EPA must explain in detail the bas I for sulfur oxide
standards promulgated under informal rulemaking); Annaconda Company v.
Ruckeishaus , D.C. Colorado, F. Suppi. , 4 ERC 1817 (Dec. 19, 1972) (EPA
must hold adjudicatory rfor 1 rulemakThg] hearing before promulgating
State sulfur oxide emission standard that applies to a single company);
International Harvester Co. v. Ruckelshaus , U.S. App. D.C.,_F. 2d_,
4 ERC 2041 (Feb. 10, 1973) (failure to support auto emission standard
with “reasoned presentation” requires EPA to reconsider automakers’showing
that technology is not available to achieve 1975 standards).
4Sec. 31l(b)(2)(B)(IV) requires EPA to establish units of measurement
based on usual trade practices, with penalties for each unlawful unit
discharged ranging from $100 to $1000 per unit.
31

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Closing the Circle on Hazardous Wastes
The foregoing discussed the many Federal and State statutes which
have impact on hazardous waste management activities. The more detailed
analyses of the Clean Air Act and the Federal Water Pollution Act illus-
trates that, while the toxic effluents of hazardous waste generation and
treatment facilities will probably come under control, land-based facili-
ties for open storage or disposal of such hazardous wastes remain
essentially unregulated. As standards and regulations published under
recent environmental legislation begin to close off water as a disposal
medium, and as enforcement of air pollution standards takes shape,
hazardous waste generators can be expected to turn increasingly to land
disposal as a means of solving their hazardous waste problems. The need
for regulations for land disposal will become more acute.
The concluding part of this section discusses the persons and
activities which would be subject to control under a comprehensive
hazardous waste regulatory program; reviews in some detail the type of
hazardous waste standards considered to be appropriate under such a
program; and identifies and evaluates the strengths and weaknesses of
three alternative regulatory program enforcement strategies.
Persons/Activities Subject to Re9ulatory Controls . In order to fore-
stall the type of environmental degradation likely to occur from the
uncontrolled use of the land as an ultimate sink for the Nation’s
ever—increasing supply of hazardous wastes, the focus of any hazardous
waste regulatory program must first be on land disposal activities
and those who provide and utilize land disposal services. Persons
subject to disposal controls should include all generators of hazard-
ous waste who opt for on-site disposal, as well as those persons who
receive wastes off-site for disposal. Long-term sealed storage should
be considered “disposal” for the enforcement purposes of such regula-
tion. The location of disposal sites should be permanently recorded
in the appropriate office of legal jurisdiction.
The next priority activity for regulation is treatment , since
utilization of the appropriate hazardous waste treatment processes
can often detoxify such wastes and render them safe for unregulated
disposal in sanitary landfill facilities or at a minimum reduce the
need for long-term “perpetual care” and environmental risks Inherent
therein. EPA has proposed a regulatory program for hazardous waste
streams which Incorporates treatment In order to lessen the demand
on land disposal alternatives. All persons who treat the same
hazardous wastes, either on-site (generators) or off-site (by contract
service organizations), should be subject to the same treatment
standards. Processes for recovery of recyclable constituents from
hazardous wastes should be controlled adequately by treatment
regulations, for the technologies employed are often the same.
32

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Other hazardous waste management activities which should be
subjected to improved controls are hazardous waste transport and
handling . As indicated earlier, the Department of Transporation
idiiiTñisters a number of Federal statutes designed to control the
transportation of hazardous materials in interstate commerce. These
statutes should be amended by DOT where necessary to ensure that
hazardous wastes are properly marked, containerized and transported
(to authorized disposal sites). The packaging and labeling provisions
of all other Federal statutes which have a potential impact on
hazardous wastes should be reviewed by EPA and amended where
necessary to ensure their applicability to such wastes.
It should be noted that control of toxic materials before they
become toxic wastes could greatly reduce the size of the overall
hazardous waste management problem. The proposed Toxic Substances
Control Act, now pending before Congress, would provide for regulatory
controls over toxic substances before they become wastes. The pro-
posed legislation authorizes (1) testing of chemical substances to
determine their effects on health or the environment, and (2)
restrictions on use or distribution of such chemicals when warranted.
Such restrictions may include labeling of toxic substances as to
appropriate use, distribution, handling, or disposal, and limitations
on particular uses, including a total ban. This “front end” approach
to toxic substances problems should dovetail neatly with a hazardous
waste regulatory program.
Types of Hazardous Waste Standards . The foundation of any regulatory
program, of course, is the body of standards the program establishes
and enforces. The Clean Mr Act and FWPCA regulatory programs pro-
gressed from ambient air and water quality standards to specific
pollutant emission and discharge standards, as practical experience
with each atute’s enforcement revealed the necessity for such an
evolution. °
Because of the nature of the discharges associated with improperly
managed hazardous waste, two types of standards are likely to be
necessary in order to satT actorily regulate hazardous waste treat-
inent and disposal:
Type of Standard Treatment Disposal
1. Performance Restrictions on quantity Restrictions on per-
and quality of waste dis- forinance of disposal
charged from the treatment site--e.g., amount,
process. quality of leachate
allowed.
2. Process Specification of treatment Minimum site design
procedures or process con- and operating conditions-
ditions to be followed-- e.g., hydraulic connec-
e.g., incineration of tions are not allowed.
certain wastes.
33

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The performance standards correspond directly to the emission/discharge
standards of the Clean Air Act and the FWPCA and would be designed to
prevent hazardous pollutant discharges from treatment and disposal
facilities from reaching air and surface waters In excess of acceptable
air and water limits. A major advantage of this type of standard is
the ability to use health and environmental effects data and criteria
already developed by EPA’s Office of Air and Water Programs and Office
of Research and Monitoring.
Process standards would be designed to ensure that certain treatment
technologies and minimum design and operating conditions are employed.
These standards assume double importance because of the uncertainty
surrounding the FWPCA’s standard-setting authority regarding discharges
into ambient groundwaters,* and the Act’s clear lack of authority to
regulate diffuse discharges from nonpoint sources such as land disposal
sites.
Process (design and operating) standards, therefore, which are intended
to establish controls at the hazardous waste sources, would be an
important part of any regulatory program.
Strategies for Hazardous Waste Regulation . Hazardous wastes can be
regulated by three distinct control stategies: (1) Federal only,
(2) State only, and (3) Federal-State partnership. Each of these
alternatives is examined below.
1. Federal only . This type of control strategy requires the
exclusive jurisdiction of the Federal Government (Federal preemption)
over all management activities for hazardous waste. The most obvious
advantages include national uniformity of standards; elimination of
State pollution havens for industries controlling a significant portion
of such a State’s economy; and uniform administration and enforcement.
The major disadvantages of this control strategy are the difficulty in
proving conclusively that the hazards of human health and the environment
justify total Federal involvement; the prohibitive costs and adminis-
trative burdens involved in maintaining a nationwide Federal monitoring
and enforcement program; and the total disincentive for State involvement
in what is essentially a State problem. The only comparable Federal pro-
gram is that involving the exclusive disposal of high level radioactive
wastes by the Atomic Energy Coninission.
*Although the broad definition given to “navigable waters” in
Sec. 502(7) of FWPCA arguably includes groundwaters, the restriction of
the Act’s regulatory provisions to discharges of pollutants from point
sources virtually eliminates the most coninon source of groundwater
pollution, I.e., runoff or leachate from nonpoint sources. See text
accompanying footnote on p. 29.
34

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2. State only . Under this control strategy, the Federal
Government would establish “reconiiiended guidelines” for hazardous
waste treatment and disposal which the States could adopt as a minimum,
modify in either direction (more or less stringent) in response to local
needs and pressure groups, or ignore altogether. These Federal guide-
lines could be used to recommend what would otherwise be process and
performance standards under a Federal regulatory program, as well as the
minimum efforts the Federal Government believes are necessary to
administer and enforce an effective State control program. States could
finance activities themselves; alternatively the Federal Government could
offer technical and financial support to assist States in program develop-
ment and enforcement.
The major advantage of this approach is in its low level of Federal
involvement and correspondingly low Federal budget requirements. Another
advantage includes enhanced ability to tailor solutions to particular
problems which may be essentially local in character.
The disadvantages of the State-only approach to hazardous waste
control include its total dependence on the States for voluntary guide-
lines’ adoption and enforcement; nonavailability of Federal “back-up”
enforcement authority; its potential for extreme nonuniformity between
the individual States adopting control programs; and the much greater
period of time needed to enact and fully implement such a control
system nationwide.
3. Federal-State Partnership . This is the control strategy which
had been adopted by the Nation’s major environmental pollution control
statutes. The Federal Government would establish minimum Federal
hazardous waste treatment and disposal standards; all States would be
required to adopt these as minimum State standards within a specified
time period. The States would bear the responsibility for establishing
and administering EPA-approved State control programs. Functions could
include operating a State-wide hazardous waste facility permit program;
maintaining an inspection and monitoring force; enforcing statutory
sanctions against violators; and filing program progress reports with
EPA. As in the Federal air and water pollution control programs, States
with approved implementation programs would be eligible for Federal
financial assistance. For those States which fail to submit approved
programs, or which do not enforce the Federal-State standards, back-up
Federal enforcement powers could be exercised to ensure uniform compliance,
or Federal program grant funds could be withheld. Provision could also
be made for a Federally-administered control and enforcement program for
certain hazardous wastes determined to pose extremely severe hazards,
an approach already utilized by the AEC for high level radioactive wastes.
35

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The major advantage of this control strategy sterns from the well-
established legislative precedents discussed earlier; land pollution
control regulations employing this strategy would be capable of being
fully integrated with existing controls over air and water pollution.
Other advantages include utilizing the Federal Government’s superior
resources to set standards and design programs, while retaining the
concept of State responsibility for what are traditionally recognized
as State problems; minimal Federal involvement once the States’
implementation programs are fully underway; uniform minimum national
hazardous waste standards, with States retaining the power to set more
stringent standards if local conditions so dictate; and reasonable
assurance that the standards will be enforced ultimately by someone.
The disadvantages of the combined Federal-State hazardous waste
control strategy involve its potential for delay in final implementation,
since States can be expected to demonstrate varying degrees of readiness
and interest In gearing up State machinery to run their respective
control programs. The major drawback to this approach, however, Involves
its potential for large expenditures of Federal manpower and funds,
should the States choose to sit back and “let the Feds do it”; even
worse is the possibility that Federal standards for hazardous waste
control will be completely unenforced in laggard States simply because of
the lack of adequate funds to exercise the ‘reserve” powers mentioned
above. This problem seems capable of resolution, however, If adequate
incentives for State action are made available (Federal grants or
technical assistance) and If significant disincentives are applied
(withholding air and water program grant funds; characterizing the
State as “irresponsible”, etc.).
Suninary
The earlier parts of this section descrIbed the gap in Federal and
State hazardous waste management legislation, a gap which If not filled
soon by Congress’ adoption of a comprehensive hazardous waste control
strategy could well result In irreparable damage to the health and
environment of the Nation’s citizens. The most viable hazardous waste
control strategy would consist of a Federal-State regulatory partnership,
in which the Federal Government would bear the responsibility for
setting process and performance standards applicable to all hazardous
waste treatment and disposal activities, while qualified State govern-
ments would be responsible for administering federally-approved control
programs and enforcing the Federal standards.
36

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Section 4
ISSUES OF IMPLEMENTATION
The previous section has spelled out the need for a regulatory
program. A hazardous waste regulatory program does not directly
create a national disposal site system” as envisioned in Section 212
of the Resource Recovery Act of 1970. However, such a system would
be ineffective unless its use is mandated via regulations. Even with
total governmental subsidy of its construction and operation, such a
system would not be assured of receiving all hazardous wastes. There-
fore, a regulatory program is needed in any case.
EPA believes that private industry will respond to a regulatory
program, but there are a number of questions relating to that response.
Furthermore, several options are available to the Government to modify
a purely private sector system to circumvent these questions if need
be.
In this section, estimates are developed of a hazardous waste
management system required to implement a hazardous waste regulatory
program, the cost of such a system, and possible variations of the
system. Issues related to cost distribution, private sector response
and the role of Government are discussed thereafter.
Hazardous Waste Mana gement System
A hazardous waste management program should result in creation
of a system” with certain characteristics:
o Adequate treatment and disposal capacity nationwide,
o Lowest cost to society consistent with public health and
environmental protection,
o Equitable and efficient distribution of cost to those
responsible for waste generation, and
o Conservation of natural resources achieved by recovery and
recycling of wastes instead of their destruction.
This system should combine on-site (point of generation) treatment
of some wastes, off-site (central facility) treatment for hazard
elimination and recovery, and secure land disposal of residues which
remain hazardous after treatment.
Scenario . Estimates of total required treatment and disposal capacity,
and the mix of on-site and off-site capacity, are keyed to hazardous
waste source quantities, types, and geographical distribution; the
degree of regulation and enforcement; and the timing of regulatory and
enforcement implementation. The hazardous waste management scenario
37

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developed below represents, in EPA ’s judgement, a system with the
aforementioned characteristics. It is Dased n he best available
source data and technology assessments 0, ‘ ‘ 0 ,discussions with
major waste generators and disposal firms, and consideration of the
following criteria: earth sciences (geology, hydrology, soils,
climatology), transportation economics and risk, ecology, human
environment, demography, resources utilization, and public acceptance.
The scenario assumes complete regulation, treatment and disposal of
all non—radioactive hazardous wastes (as defined in Appendix B), and
anticipates issuance of regulations and vigorous enforcement of them
at the earliest practicable time period.
The scenario which follows and the cost estimates derived from
the scenario should be viewed with caution. Given any reasonable
degree of dependence on private market choices on the part of waste
generators and waste treatment/disposal firms, the actual implementation
of a hazardous waste management program in the United States is not
likely to follow predictable, orderly lines. Numerous interactive
factors are likely to influence the shape and the cost of the system
as It evolves--including such factors as the impact of air and water
effluent regulations on waste stream volume and composition, the impact
of uneven response to regulatory pressures from region to region,
changes in technology, shifting locational patterns, and the like.
What follows, therefore, should be considered as one of many possible
permutations of the system. Nonetheless, the scenario does represent
EPA’s current best judgement of a reasonable, environmentally adequate
hazardous waste management system.
As noted previously, approximately 10 million tons (9 million
metric tons) of non-radioactive hazardous wastes are generated per
year. Of these, about 60 percent by weight are organics, 40 percent
are inorganics; about 90 percent of wastes are aqueous in form.
Economic analyses indicate that on-site treatment is generally
justified only for dilute aqueous toxic metal wastes and only where
the generation rate is high (see Appendix E). Based on analyses of
source data, it is estimated that about 15 percent of the total wastes
(1.5 million tons or 1.36 million metric tons) are in the dilute
aqueous toxic metal category and would be pre-treated by generators
on—site. Since on—site facilities are anticipated to be small in
scale compared to off-site facilities, about 50 on-site facilities
each capable of handling approximately 30,000 tons (27,000 metric tons)
per year would be economically justified. About one-third (0.5 millIon
tons or 0.45 million metric tons) of pre-treated wastes would require
further processing at off-site facilities.
In this postulated scenario, therefore, most of the wastes
(8.5 mIllion tons or 7.7 million metric tons plus pre-treatment
residues) would be transported to off-site facilities for treatment/
38

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disposal. The size and location of treatment plants is likely to
correspond to patterns of waste generation: larger facilities would
be located in major industrial regions, smaller facilities elsewhere.
Background studies have identified the location of industrial waste
production centers and designs and unit costs of small, medium and
large size processing facilities (see Appendix F).
A reasonable prediction is that five large facilities,each capable
of handling approximately 1.3 million tons (1.2 million metric tons)
per year,would be created to serve five major industrial regions in
the U.S. and 15 medium size treatment plants each processing approxi-
mately 160,000 tons (145,000 metric tons) would be built elsewhere
to provide reasonable access from other waste generation points. Such
an array of treatment plants, taken in conjunction with existing privately
owned facilities, is capable of processing all the non-radioactive
hazardous waste generated in the U.S. at present with a 25 percent
margin for future growth in waste volume.
Processing reduces aqueous waste volume by about 50 percent and
usually results in the elimination of hazard (detoxification, neutra-
lization, decontamination, etc.). If the appropriate treatment
processes are used, most processing residues will be harmless and
disposal in ordinary municipal landfills will be possible. A small
portion (5 percent--225,000 tons or 204,000 metric tons) of residues
containing toxic metals would require disposal in special, secure
landfills.
Under the assumption that maximum treatment for hazard elimination
and volume reduction of extremely hazardous waste is carried out, no
more than five (and possibly fewer) large scale secure landfills would
be required. Facilities would transport their toxic metal residues to
such land disposal sites rather than operating secure landfills of
their own given the scarcity of naturally secure sites, the difficulty
in gaining public acceptance of such sites, the additional expense of
artificially securing sites, and the relatively low costs of long-haul
transport.
Costs . Based on the above scenario, cost estimates have been prepared
for on- and off—site treatment facilities, secure disposal, and waste
transportation. The actual values used for estimation purposes are
shown in Table 4.1; more detail is presented in Appendix F. Estimates
are based on comprehensive engineering cost studies. Each regional
processing facility was assumed to provide a complete range of treat-
ment processes capable of handling all types of hazardous wastes, and
therefore, each is much more costly than existing private facilities
which are more specialized.
Based on these estimates, the development of this version of a
national hazardous waste management system would require investments
in new facilities of approximately $940 million. Average annual
39

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Table 4.1
Cost Aspects of EPA Scenario of a National
Hazardous Waste Management System
(Million $)
* Includes capital recovery in 10 years and interest at 7 percent.
t Capital required based on new rail rolling stock.
Transport required for 9.0 million tons (8.25 million metric tons) of waste;
average distance from generator to treatment facility is 150 miles.
Approximately $25 million has already been invested in current private sector
off-site treatment facilities.
Cost
per unit
Total
Capital
Annual
Number
Capital
Needed
1.4
Operating*
Needed
51
Required
71
.73
On-site facilities
Off-site
Treatment (large)
Treatment (medium)
Secure Disposal
Transport
86.0
24.1
2.5
63. Ot
57.1
12.5
1.2
$11/Ton
5
15
5
Total
Annual
Cost *
37
286
188
6
99
616
430
362
13
63
9 39**
40

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operating expenditures (including capital recovery, operating costs,
and interest) of about $620 million would be required to sustain the
program. In addition, administrative expenses of about $20 million
annually for Federal and State regulatory programs would be necessary.
For this scenario, system costs fall into five broad categories:
(1) on—site treatment (about 6 percent of total costs on an annualized
basis), (2) transportation of wastes to off-site treatment facilities
(16 percent), (3) off-site treatment (74 percent), (4) secure disposal
(1 percent), and (5) program administration (3 percent). The largest
element of cost is off-site treatment. Treatment followed by land
disposal of residues is not necessarily more expensive than direct
disposal of untreated wastes in secure landfills (see below).
Treatment before disposal would buy greater long-range protection of
public health and the environment.
Variations . While the above scenario is reasonable and would satisfy
requirements for environmentally adequate hazardous waste management,
It is not presented as a hard-and—fast specification of what a nationa1
system should look like. There is no single 9 optimum M system given
uncertainties of hazardous waste generator response to air, water and
hazardous waste regulations, of future directions In production and
waste processing technology, of timing and level of enforcement, of
public reaction to site selection decisions, etc. However, some
con nents can be made about variations in the system scenario presented
above.
It is unlikely that more large scale and fewer medium scale
processing facilities would be constructed unless specifically
mandated. The higher initial capital investment of large scale
processing facilities is warranted only where large market potential
exists, I.e., In the major industrial regions. Furthermore, at
present, addition of only two more large scale facilities (over the
five in the scenario) would provide sufficient capacity to treat all
non-radioactive hazardous wastes. Stated another way, two more large
scale facilities could handle all the wastes for which 15 medium
sized facilities were postulated in the scenario. Resulting increased
costs of transportation from generators to these larger treatment
facilities (because average transport distances would increase) would
offset cost reductions due to better economies of scale (see
Figures 4.1 and 4.2). The net result would be a significant loss in
convenience and Increase in transportation risks for a fairly insignif-
icant saving in capital cost and a higher operating cost.
Construction of a larger uumber of medium or small scale plants
(and consequently fewer large scale plants) tends to drive capital
costs up sharply (see Figure 4.1). Total system operating costs also
rise because transportation cost savings are not sufficient to offset
lost economies of scale (see Figure 4.2). TransportatIon risk would
41

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Figure 4.1
2,800 FIxed Capital Cost Sensitivity of a National Hazardous
Waste Management System to Fluctuations In Nunter and Size of Facilities 273S
Legend:
2,400 L — Large facility, processing 1,330,000 tons (1,210,000 metric tons) per year
14 - Medium facility, processing 162,000 tons (147,000 metric tons) per year 20M + 176S
S Small facility, processing 33,300 tons (30,200 metric tons) per year —
2,000
4014 + 76S
1,600
56M
1L+48M
4- 21+4014
i nn 31+3214
41+2414
5L+15M —
71 6L+714 —
• 800 — —
4 .,
U,
0
C-)
400 800 851 939 1070 1176 1234 1392 1497 796 246 2665
! ncreasingjy _ Smaller Facilities
Note: Each configuration includes $71 million for on-site facilities; $13 million for secure land disposal;
and from $41 to $114 million for new transportation equipment (based on average distance and estimated
turn-around time).

-------
FIgure 4.2
Operating Cost Sensitivity of National Hazardous Waste Management
System to Fluctuations in Nunler and Size of Facilities
Legend:
L Large facility, processing I ,330,000 tons (1 ,210,000 metric tons) per year
M = Medium facility, processing 162,000 tons (147,000 metric tons) per year
S = Small facility, processing 33,300 tons (30,200 metric tons) per year
40t1 + 76
(932)
51 + 15M
(616)
99
517
572
& disposal 11
21 + 40M
31 + 32M
(714)
(671)
— 56
61 —
16 658
+ 48M
(751)
50
701
56M
(78$)
745
893
2 73S
(1334)
20M + 176S
(1142)
1103 296
1,400
1,200
1 ,000
800
600
400
200
Transportation
I-
w
‘V
I .-
0
C
0
C
r
In
0
7L
(627)
4L + 24M
(639)
67
6L + 7M
(603)
474
184
443
Increasingly Smaller Facilities
Note: Each configuration includes $37 million In annual costs for on—site facilities and $6 million for
secure land disposal.

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decline due to shorter haul distances, but inspection and enforcement
costs would increase due to the larger number of plants requiring
surveillance. As discussed below, however, a private sector system
may consist of more smaller plants and thus may result in higher total
costs.
There could be fewer disposal sites than assumed in the scenario
if land availability/suitability and public acceptance problems arise.
This outcome is likely if, for instance, only arid lands with no
hydrologic connection to surface and ground waters are deemed acceptable
as disposal sites, i.e., if disposal siting standards are extremely
strict. Transportation costs would increase somewhat, but not linearly
with distance. For example, rail transport costs are estimated at $35
per ton for 1,000 miles and $49 per ton for 2,000 miles distance.
Transport risks would be greater, but disposal risks and enforcement
costs would decline because fewer sites would be easier to monitor.
On the other hand, as a policy decision, the Government could
allow significantly more disposal relative to processing. Many more,
or at least much larger, disposal sites would be required in this case
since, for Instance, approximately a forty-fold Increase in tonnage
going to secure disposal sites would result if processing were by-passed
althgether. The total system capital cost would be reduced since treat-
ment represents a large capital expense (see Table 4.2). If disposal
siting standards were very strict such that arid lands in the western
States were the only acceptable sites, transportation costs would increase
substantially because of the large increase in tonftage transported over
longer distances. In fact, in this case, annual operating costs for
this “disposal only” option exceed annual costs for the treatment!
disposal system scenario discussed above.
Aside from economic considerations, what is more important in EPA’s
judgement is that the “disposal only” option could significantly
increase public health and environmental risk, perhaps to an unacceptable
level, given the long-term hazard of many toxic substances, particularly
if such substances are not converted to relatively insoluble forms
prior to disposal. Moreover, transport risks would undoubtedly
Increase.
Cost Distribution to Users
Given a hazardous waste regulatory program, and the need for a
hazardous waste management system to implement such a program, the
fundamental issue is who should pay for creation and operation of the
system. The two basic options are:
• Hazardous waste generators pay, or
• Society pays.
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Table 4.2
Comparative Costs of Regional Hazardous Waste
Treatment vs. Disposal Only
Regional Disp sal
Treatment* Only
(A) TREATMENT
Hazardous waste treatment on-site, million tons 1.0 0
Hazardous waste treatment off-site, million tons 9.0 0
Treatment cost, fixed capital $863 million $ 0
Treatment cost, annual operating $511 million/yi $ 0 /yr.
(B) DISPOSAL
Secured land disposal, million tons .225 10.0
Disposal cost, fixed capital $13 million $386 million
Disposal cost, annual operating $6 million/yr $257 million/yr
(C) TRANSPORTATION
Transportation cost, fixed capital $63 million $252 million
Transportation cost, annual freight charges $99 mi11ion/y $490 million/yr
Total fixed capital $939 million $638 million
Total annual costs $616 million/yi $747 million/yr
* As described on p. 39.
j Cost data for this option are based on two ‘arge secure land disposal
sites-- both in the western States. 10 x 10 tons per year of untreated
hazardous waste is shipped directly to these sites.
The average distance between waste generators and secure land disposal
sites is 2,000 miles.
Note:
Secure land disposal costs are based on preliminary OSWMP estimates.
The indicated transportation costs represent a minimum, because bulk
shipment via railroad in 10,000 gal. tank cars was assumed for all
cases.
45

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This issue hinges on the principle of equity of cost distribution, and
on an assessment of ability to pay.
Equity of Cost Distribution . The usual aim in environmental legislation
is to cause costs to be internalized . Costs are internalized when the
generator pays the full costs of actions for which he is responsible.
In turn, he can either absorb the costs (“taxing’ t his stockholders) or
pass on the costs in the price of his products/services (“taxing” those
who benefit from the use of his products/services). Only those who
have a direct relationship to the generator are required to pay for
the generator’s actions.
A publicly funded incentive distributes the costs inequitably by
assigning costs incurred by a special group to the population at
large--not in proportion to the use of waste-related products by that
public but in proportion to income levels.
The regulatory approach internalizes the costs of hazardous
waste management. It forces generators to pay for such management
while it ensures that the practices are environmentally acceptable.
The only portion of the program’s cost that must be borne by the
public as a whole is the small portion devoted to the actual preparation
of the regulations and their enforcement, and the management of wastes
generated by the Federal Government.
The regulatory strategy, therefore, results in equitable cost
distribution. Only those institutions and individuals who benefit
directly from the activities of hazardous materials production and
consumption are required to bear the costs of waste disposal, and
the costs borne are directly proportional to the amount and type of
wastes generated.
Most hazardous wastes are generated by Industry and the Federal
Government rather than municipalities. The strategy adopted for
dealing with air and water pollution from industrial sources has
been the regulatory strategy. Thus, this approach is consistent with
the total thrust of environmental control efforts. A subsidy
strategy to industry would represent a new departure.
It could be argued that if some sector of the economy is unable
to bear the costs of a regulatory program by nature of Its institu-
tional situation, fiscal support of that sector may be justified to
enable it to meet the regulatory requirements without serious harm
to the economy or interruption of vital services.
However, generators of most hazardous wastes are either private,
profit-making industrial organizations or governmental entities.
Private corporations are capable of accepting the additional costs
of environmental control that may be imposed by a hazardous waste
regulatory program. They have the option of passing on such costs
to their customers or absorbing the costs by reducing the return On
investment to their owners. Government agencies have the usual
capabilities available to such entities to seek budgetary support
46

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for legally mandated activities. Neither sector would fall into the
‘ 1 hardship” category if it had to pay the full costs of its waste
generation.
Analysis of Cost Impacts . No detailed study has yet been performed
to determine the cost burden of specific hazardous waste regulations
relative to the sales, costs, investment levels, and employment
levels of the industrial sectors which would be affected. Rough
aggregate calculations have been done for the following sectors:
chemicals, chemical products, petroleum refining, rubber production,
ordnance, primary metal industries, pulp and paper, and mining. These
aggregate calculations indicate that the costs of hazardous waste
management would be roughly equivalent to 1 percent of the value of
product shipments. Of course, the corresponding percentage for some
disaggregate categories may turn out to be much higher.
A general principle which recurs throughout this report is that
the costs of hazardous waste management should be internalized in
the prices of the comodities whose production has generated the
hazardous waste. This principle is consistent with the President’s
environmental messages. The results of preliminary studies do not
indicate that hazardous waste management costs would cause drastic
industrial disruption. EPA is giving a high priority to detailed
analysis of the costs and cost impacts of hazardous waste management.
Benefit-Cost Analysis . Given the cost and price impacts which
hazardous waste regulations could impose, careful consideration is
being given to benefit—cost analyses. Hazardous waste regulations
may be said to be “benefit determined” in the sense that they cover
situations In which the benefit to society in the form of a hazard
reduction is shown to be large. Thus, the first type of benefit-
cost comparison is that involved in placing a hazardous waste on the
regulatory list, as a result of demonstrating that some regulatory
option is preferable to the status quo. The second, and equally
important, type of benefit-cost analysis is the comparison of all the
options, each one involving different levels of benefit and cost.
One may speak rhetorically about rendering a substance completely
harmless, but in fact that is only one option. That option may have
to be chosen in cases for which the associated benefits are large
In other cases, cost-benefit comparisons may support a different
process alternative. To the extent possible, EPA tends to use cost-
benefit analyses to explore the full range of technological options
for each hazardous waste.
Role of the Private Sector
As discussed earlier, processing economics appear to favor
off—site treatment/disposal in most instances. A private hazardous
waste services industry exists which already offers off-site treatment/
disposal services, but currently available off-site capacity is clearly
Insufficient to handle the entire tonnage of hazardous waste materials
47

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that would ultimately be brought under control. In light of this,
it is obvious that off-site capacity must be significantly expanded
if environmentally adequate hazardous waste treatment and disposal
is to take place.
EPA believes that private industry should and will respond to the
proposed regulatory program, but there are a number of questions
related to the nature of that response:
O will adequate capacity be forthcoming?
o Can environmentally sound operations be assured?
o Can reasonable user charges be assured?
- ° Can the private sector provide long-term care of treatment,
storage and disposal sites?
These questions are taken up in what follows. The general issue
of the government’s role is discussed separately.
Capacity Creation . The central question is whether or not a regulatory
program will result in sufficient investment iA new capacity by the
private sector. Basic issues of capacity creation include the
availability of investment capital and the willingness to invest
capital in view of the risks involved, i.e., the factors influencing
investment. Related to the broad question of private investment are
other issues dealing with the availability of trained manpower and
the availability of suitable land for facility siting. These issues
are discussed below.
Private Investment Sources . Under a regulatory program capital
is likilj to be avaflibli from at least three private sources:
hazardous waste service firms, generators, and solid waste management
conglomerates.
In the initial stages of a regulatory program (e.g., the first
year), no major new investments are likely to be required. Existing
service firms will respond to new demand by increasing their throughput.
Soon, however, demand Is likely to outstrip supply of such services in
a climate of vigorous enforcement, and new investments will be required.
The ability of present service firms to provide internal capital
and to attract outside investments has been limited because of
generally poor earning records in the past. This situation results
from the absence of regulatory and economic Incentives for generators
to utilize their services. Increased regulatory activity, however,
should improve the fiscal abilities of these companies over time by
increasing their rate of facility utilization and (under conditions
48

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of strong demand) by increasing the prices they can command for
services. In fact, the rates of utilization and earnings rates
of most of these firms have been increasing as industries respond
to water pollution control regulation. This will improve the
ability of this industry to retain earnings for investment and also
its ability to attract outside capital. This source of capital,
however, is expect Ito be limited in the early years of a regulatory
program.
Two other sectors of the economy, however, are expected to
become more involved in capacity creation and to attract substantial
investment capital to the field.
Major generators of hazardous wastes--e.g., the chemicals and
metals industries--will have a strong interest in assuring that
off—site facilities will be made available for their use because
off-site handling will be more economical. These financially strong
organizations--some of which already operate treatment/disposal systems
for their own use-—may enter the service field by acquisition or other
routes or may underwrite the activities of others by provision of
long-term contracts or use of other devices.
During the past five years large and financially strong private
solid waste management ‘ t conglomerates have emerged, offering
management services for nonhazardous wastes. These organizations
have established strong lines of credit at attractive interest rates.
Although most of these firms lack the technical know-how to manage
hazardous wastes today, they are likely to acquire know-how and to
enter this field under the stimulus of a regulatory program in a
logical extension of their current services to industry. Some have
already established a position in this field by the acquisition of
hazardous waste management subsidiaries.
From the above, it is concluded that sources of private capital
to build new capacity potentiallyis available. This does not mean,
however, that it will be forthcoming.
Factors Influencing Investment . Private sector investment in
hazardous waste management facilities entails significant risks, and
these risks generally increase as the size of the proposed facilities
increase. There are uncertainties regarding waste generator response
to air, water and hazardous waste regulations; generators may install
new production processes which result in fewer wastes or wastes with
different characteristics; generators may elect to treat wastes
on-site; future breakthroughs in processingtechnology may prematurely
obsolete the proposed plant; further environmental standards may
impact on the proposed plant; economic forces may eesult in geographical
shifts in waste generator plant locations; and there are uncertainties
relating to the future activities of competitors.
49

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These factors may (I) deter investment of any kind, (2) lead
to investment in treatment processes only for wastes generated in
high volume or for wastes which are relatively inexpensive to treat,
(3) lead to investment in smaller, less risky facilities which are
more expensive to operate on a unit cost basis, or (4) lead to
processing plant siting only in locations where major industrial waste
sources are assured.
In view of these uncertainties, the degree and timing of private
capital investment in new capacity will depend heavily on the quantity
of waste regulated and the level and timing of enforcement. Also,
the ultimate private sector network which results may include many
smaller facilities and therefore represent, in the aggregate, a more
expensive system than the scenario depicted.
Quantity of Waste Regulated . Regulations which affect a significant
tonnage of waste will spur investments more than regulatory activity
aimed at a small proportion of the Nation’s hazardous wastes.
A regulatory program is most likely to be aimed at the control
of specific waste con ounds rather than the waste streams in which the
con ounds occur. Justification of regulatory action must be tied to
health and environmental effects, which can be established moit conclu-
sively by studying the effects associated with specific chemicals.
Unlike the regulator, the generator must dispose of and the service
firm must manage waste streams which may contain a number of hazardous
substances in mixture.
Background studies performed for EPA have provided useful data on
the composition of waste streams. These data indicate that regulatory
control of a limited number of the most hazardous substances could re-
suit in the treatment/disposal of a substantial proportion of the total
waste stream. Several hazardous substances are usually present in
chemical and metallurgical hazardous waste discharges, and selective
treatment of one or two components of the waste does not appear to be
economical. Not all hazardous substances must be regulated imediately,
in other words, to cause most wastes to be treated/disposed of under
control led conditions.
This suggests that regulatory activity can move ahead based on
regulation of groups of a few substances at a time--in a manner similar
to that adopted to implement the hazardous effluent provisions of air
and water mandates--while still ensuring that substantial quantities Of
hazardous wastes will be treated.
50

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Level and Timing of Enforcement . The key to capacity
creation appears to be vigorous enforcement of regulations to
force the use of existing capacity by generators. Enforcement
of regulations wherever possible will impose costs on generators
which may exceed costs of treatment/disposal in new facilities
more appropriately located relative to regions of waste
generation and will build pressure for rapid investments. Such
enforcement will also create incentives for new ventures by
ensuring markets for services.
The regulatory approach most likely to result in private
investment would be one which encouraged incremental additions
to capacity by mandating their use as soon as they are created.
The approach should be tied to a terminal date by which all
regulated wastes must be managed as mandated.
The “incremental” approach has the drawback that it initially
impacts more heavily on generators which are near existing treat-
ment/disposal facilities. Thus, other generators which have no
such services available to them have a potential advantage. However,
the approach protects the public and the environment as soon as
possible wherever it is possible.
The above approach is contrasted to a strategy where
regulations are announced at one point in time but provide
some “reasonable” time for creation of capacity nationwide by
generators or their agents before any enforcement takes place.
This latter approach would provide fewer incentives for invest-
ment in increments of capacity and, by “bunching” capital demand
in the “reasonable” waiting period, would also tax the fiscal
capacities of industry to respond. If no capacity is created
by the deadline period, appeals to delay enforcement would be
likely.
In sumary, timely investment of private capital to create
capacity is anticipated if the regulatory program affects a sub-
stantial portion of the Nation’s hazardous wastes and if a
vigorous but incremental enforcement approach over time is adopted.
These conditions will assure an investor that the facilities he
builds will be used, but will avoid excessive demands on available
capital at the outset of the program.
Government activity in some fiscal role can potentially speed
up timing of Investments by private service firms where high
Investment risks must be overcome; this is discussed below in more
detail. A governmental fiscal role, however, is also subject to a
number of constraints.
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Availability of Manpower . The technology of hazardous waste
processing is capital intensive and a significant increase in
capacity will require only a limited expansion of labor.
Much of the expertise required for the expansion of the hazardous
waste management industry already exists in the metallurgical and
petrochemical industries and the engineering and construction firms
that service these.
Similarly, the skills required at local, State, and Federal levels
of government are essentially the same as those necessary for the
operation of air and water pollution control programs.
Capacity creation is not thought to be constrained by a shortage
of manpower under any reasonable implementation time-frame, Eor example
five years.
Availability of Land . Land suitable for the siting and operation
of hazardous waste treatment facilities has been identified as part of
EPA’s background studies (Appendix F). There is no shortage of
appropriate land for treatment facilities in the vicinity or imediately
within the Nation’s major hazardous waste generation regions.
Land used for disposal by burial should be “secure,” i.e., it
should be sealed off from underlying ground waters by Impervious
materials. Ideally, such sites should be located in areas where the
cumulative precipitation is less than the evapotranspiratfon so that
rain cannot accumulate in the “sealed landfills. Such conditions
prevail only in the western desert regions.
Ideal conditions for disposal sites need not be present if the
secure landfill is located near hazardous waste treatment plants
where water accumulations can be removed from the disposal site and
treated in the plant. Sites with appropriate geological features are
available in areas other than the western States.
Probably the most important potential problem associated with the
land-use aspect of hazardous waste management is that of public
resistance to the location of such facilities in their comunities.
Although EPA’s public attitudes survey indicates public support of
central treatment and disposal of hazardous wastes under controlled
conditions, It is not at all certain that the public will express the
same attitude when faced with an actual siting decision.
While siting problems are anticipated by EPA, there are indications
that such constraints can be overcome. The private hazardous waste
management industry and AEC contractors have been able to obtain sites
in most cases. Treatment and ultimate disposal facilities will
represent employment in areas which are of necessity low in population
density (if sites are chosen to minimize safety hazard) and in need
of industrial development.
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Environmentally Sound Operation . The private sector, following a
profit motive, has incentives to run only as good a hazardous waste
management operation as it takes to obtain and keep business and to
comply with governmental regulations. Customers may demand more
stringent operations to benefit their image or for legal and other
reasons, but the private sector hardly can be expected to go all out
to maximize the environmental soundness of its operations.
It is anticipated, however, that environmentally acceptable
operation of private facilities can be assured by appropriate govern-
mental and citizen activities. The basic standards and regulations
governing hazardous waste management operations must not only be
environmentally adequate in themselves but also must provide for
effective administrative and legal sanctions against potential
offenders. Adoption of appropriate criteria for facility licensing
can filter out candidates who do not possess resources sufficient to
provide sound facility construction, operation, maintenance and
surveillance. Vigorous inspection and enforcement by government, with
the attendant threat of licensing suspension or revocation actions,
can assure sound operations over time.
If the regulatory legislation contains provisions for citizen
suits, which is likely given the trend of recent environmental
legislation, citizens may bring legal pressure to bear on both the
government and private industry to force compliance with existing
Federal, State, and local regulations.
Reasonable User Char g s . The issue of whether or not a private market
situation ifli result in reasonable user charges is dependent upon
quite complex interactions involving facility scale and location, risk,
competition and transportation rates.
As has been discussed, significant economies of scale are possible
in the processing of toxic waste. To the extent that such economies
are realized and passed on to users of processing facilities, user
charges will be “reasonable.° To the extent economies of scale are
not achieved or that economies are achieved but savings are absorbed
as monopoly profits, charges for the use of processing facilities may
be unreasonable.
Unfettered operation of the market system may not result in the
construction of plants of optimal size initially. Due to a desire to
minimize or avoid the risk factors discussed earlier, there may be a
tendency to build a number of small, high unit cost plants where one
large economical plant would suffice. On the other hand, although small
plants may result in higher unit costs of operation, their lower
investment requirements may spur competition and reduce opportunities
for monopoly profits. Thus, in the scenario described earlier in which
large plants with large investment costs and low operating costs
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predominate, there is potential for monopolistic behavior and,
consequently, unreasonably high profits and user charges. The
possibility of monopoly are increased by the relatively few
companies nationally which have the resources and technical quali-
fications to enter this field.
Factors other than the risks associated with large investments
tend to counter monopolistic behavior, however. Given the relatively
low cost of transport in comparison to processing costs and the
relative insensitivity of transport charges to increase in haul
distances, trade-offs between transportation charges and at-the—plant
user charges should result in some overlap among service regions and
thus should stimulate competition. A second potential limitation on
unreasonably high user charges is the ability Of waste generators to
operate their own waste processing plants if projected processing
charges appear excessive. Also, the Federal Government could use the
processing and disposal of its own wastes, which would be sent to the
low bidder on a service contract, as leverage to keep charges
reasonable. The revenue and cost information which the Federal
Government typically requires as part of the procurement process
should itself provide a means of tracking the reasonableness of
processing charges on a continuing basis.
Although it is difficult to predict how these opposing forces will
operate under a free market situation, there is no indication at this
time of the need for additional government control (beyond that derived
from Federal Government procurement) of hazardous waste service charges.
Competition exists now in the general absence of specific hazardous waste
regulations, and additional competition is anticipated If new regulatory
legislation is passed. Overall system costs, even If many small plants
are the rule (see Figure 4.2), should not be so unreasonably high that
they merit Federal Interuention.
Long Term Care . As indicated earlier, some non-radioactive hazardous
wastes cannot be converted to an innocuous form with presently
available technology, and some residues from waste/treatment processes
may still be hazardous. Such materials require special storage or
disposal and must be controlled for long periods of time.
In some respects such materials resemble long-lived radioactive
wastes; both are toxic and retain essentially forever the potential
for public health and environmental insult. There are differences,
however: non-radioactive hazardous wastes normally do not generate
heat nor do they require radiation shielding.
Until recently, essentially all radioactive wastes mere generated
by the Federal Government itself as a result of the nuclear weapon,
naval propulsion and other programs. This established a precedent for
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Federal control of radioactive wastes which has carried over to the
commercial nuclear power generation and fuel reprocessing industry.
No such precedent exists for non-radioactive hazardous wastes from
industrial sources.
The AEC has established the policy of “engineered storage” for
long—lived radioactive wastes because of difficulties in assuring
long-term control of these wastes if they are disposed of on or under
the land or in the ocean. Designs of such storage facilities will
vary with the nature of the wastes involved, but the general principle
is to provide long-lived containerized or otherwise separated, easily
retrievable storage units. These units generally will require heat
removal, radiation shielding, surveillance, and security.
The storage/disposal facility requirements for non-radioactive
hazardous wastes are anticipated to be less severe than for radioactive
wastes since heat removal and shielding are not required, but many of
the problems remain. Such facilities should be “secure’ t in the sense
that there are no hydrologic connections to surface and ground waters.
Long term physical security and surveillance of storage and land
disposal sites are required. Also, there should be contingency plans
for sealing off the facilities or removing the wastes if hydrologic
connections are subsequently established by earthquakes or other
phenomena.
From an institutional viewpoint, the private sector is not well
suited for a role in which longevity is a major factor. Private
enterprises may abandon storage and disposal sites due to changes in
ownership, better investment opportunities, bankruptcy, or other
facthrs. If sites are abandoned, serious questions of legal liability
could arise. This issue led the State of Oregon, in its recently
adopted hazardous waste disposal program, to require that all privately
operated hazardous waste disposal sites must be deeded to the State
and that a performance bond be posted as conditions for obtaining a
license to operate such sites.
Traditionally, waste generators pay a one-time fee for waste
disposal. If this concept were carried over to hazardous waste
disposal, priiate operators of disposal sites would have to charge
fees sufficient to cover expenses of site security and surveillance
for a long, but indeterminant, time period. Another option would be
to consider hazardous waste disposal as a form of long term storage.
Generators would then pay “rent” in perpetuity. Given uncertainties
of future market conditions, inflation, etc., neither of these options
would have appeal to either the waste generator or disposer, nor would
the options preclude legal problems if either party were to file for
bankruptcy.
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There are grounds, therefore, to consider the role of the
private sector in hazardous waste storage and disposal as funda-
mentally different in character from its role in hazardous waste
treatment. EPA believes that, given a regulatory stimulus, the
private sector can and will provide necessary facilities for hazardous
waste treatment which are operated in an environmentally sound manner
with reasonable user charges. However, the issue of long term care
of privately owned and operated hazardous waste storage and disposal
sites poses significant problems not easily resolved. Some form of
Federal or State intervention may be required. These options are
discussed in what follows.
Role of Government
The Implementation strategy described above assigns to government
the limited role of promulgating and enforcing regulations. In view
of the potential problems discussed above, however, a more extensive
government role may be justified under certain circumstances. Options
for more extensive government intervention which might be determined
to be required include:
• Performance bonding
• Financial Assistance
• Economic Regulation
• Use of Government land
• Government ownership and operation of facilities
These options are discussed below.
Performance Bonding . The government could require a performance bond
of private firms as a condition of issuing a license/permit for
operation of hazardous waste treatment or disposal facilities. The
bond would help to ensure environmentally sound operation of processing
facilities and long term care of disposal sites. This system Is used,
for example, by the State of Oregon for all hazardous waste disposal
sites and by the State of Kentucky for radioactive waste disposal sites.
Performance bonding presents a paradox, however. The bond must
be large to be effective, but the larger the bond, the more likely
it Is to inhibit Investment. Used unwisely, the performance bond
concept could result In no private sector facilities, or in a
monopolistic situation with a very limited number 0 f large firms in
the business.
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EPA believes that a performance bonding system, wisely applied,
could be beneficial in establishing the fiscal soundness of applicant
firms (if fiscally weak, the firm could not be bonded). The bonding
system could be adopted within a regulatory program in the licensing
procedures with very little, if any, cost to government.
Financial Assistance . Some form of fiscal support of capacity creation
may be justified if the private sector fails to invest the capital needed
for new facilities. If that happens, environmental damage will continue
and the potential hazard to public health and safety will increase.
Current indications are that private capital will begin to flow
under a regulatory approach. It may be argued, however, that capital
flow may be slow and uneven on a national basis. In some areas
capacity may be created, in others not. Investors might play a wait-
and—see game because of potential risks, etc. In such a situation
governmental fiscal support might speed up implementation or ensure
that all generators have facilities available for use.
A governmental fiscal role in capacity creation is not warranted-—
on equity and other grounds discussed earlier--unless capital flow is
actually very slow and adverse environmental effects are resulting
from the Investment rate. If support is warranted, various types of
support are likely to have different effects.
Indirect Support . A loan guarantee program, probably the most
indirect form of fiscal support available, may be more effective in
speeding up implementation than direct, massive support of construction.
If capital is available (in the absolute sense), but is not obtainable
practically because of risks associated with investment in such
ventures, a loan guarantee program can induce investments by removing
or cushioning the risk. At the same time, such a program would be less
vulnerable to budgetary constraints and less likely to lead to a slowdown
in private investments than direct support.
A loan program, while preferable to direct support on equity
grounds, would depend on budget availability and would act to slow
down implementation.
Other indirect approaches, such as investment incentives based
on investment credits or rapid write-off provisions, are comparable to
& loan program in that they have a budgetary impact (by affecting
government tax income) but would be less likely to slow down imple-
mentation because no positive budgetary action would be required to
Implement such support.
These approaches, much like direct support, would be difficult to
justify for a part of the nation only--that is, to support building of
capacity only in areas where private action is not resulting in
construction.
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Direct Fiscal Support . Such support might conceivably take the
form of construction grants or direct government construction of
facilities. Such action can ensure capacity creation. Programs of
this type, even in the environmental area, have often failed to meet
originally established timing goals because of budgetary constraints
and other factors. To the extent that local government involvement
is sought in a Federal program, a further potential for delay is
introduced. The availability of public funding also has a stifling
effect on private initiative. It is economically unwise to invest
private money if public funds are available.
This approach, while it can guarantee that ultimately capacity
will be built, does not promise to be effective in speeding up the
implementation rate. Where the objective is to provide capacities
in regions where investments are lagging, direct fiscal support is
extremely difficult to justify for only one area to the extiusion
of others.
The advisability of government construction support may also be
viewed In the conteRt of government couipetltion with private industry.
A fledgling service industry exists. These firms uld object to the
entrance of the government into the field as a competitor (direct
ov rnment construction) or government action to set up colTpetltlon
(grant programs). To the extent that private resources have already
been coninitted to this field, grelt care wouTd have to be exercised
to avoid driving existing firms out of the market with the resultant
economic loss to the Nation. It may be necessary on equity grounds
to compensate existing companies for their investments--by outright
purchase or post-factum grant support. Determining the value of these
companies 1 investments may be difficult in the face of probably increasing
demand for their services.
Economic Regulation . The Congress could mandate a hazardous waste
management system patterned after the public utility concept. In
this type of system, government could set up franchises with territorial
limits and regulate user charge rates.
The hazardous waste management field shares many characteristics
of eurrently regulated industries In any case. There are public
service aspects, relatively few plants are required per region, and
these facilities are capital-intensive. Further, there is potential
for natural geographic monopolies because barriers to a second entrant
In a given region are high.
Government control of plant siting, scale and rates could lessen
the potential for environmental impacts and provide greater incentive
for private sector investment since there would be no threat of
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competition and consequently less risk of failure. On the other hand,
some companies may not enter the field on a utility basis because of
potentially lower rate of return on investment. Further, lack of
competition could inhibit new technology development.
Ec nomic restrictions can be applied directly via a governmental
franchise board or commission or indirectly via administrative actions
such as licensing and permitting. GoverAment control of franchising
shifts the burden of market determination and related business decisions
into the public sector which is not inherently better equipped to make
such decisions than private industry.
Licensing and permitting of treatment/disposal facilities appears
to be a better approach for the exercise of economic control since
they can be used to influence (rather than dictate) plant locations,
sizes and rates. Some form of government control over such facilities
Is desirable in any case to ensure their proper operation.
Administrative rather than direct regulatory actions would be
less costly to government. New legislation would be required to
authorize either direct or indirect economic sanctions.
Use of Federal/State Land . Although suitable sites for hazardous
waste processing facilities are generally available to the private
sector, adverse public reaction to such sites may preclude their use.
If this occurs, It may be necessary to make public land available to
private firms. These lands could be leased or made available free of
charge depending on circumstances. As noted earlier, the State of
Oregon requires that hazardous waste facilities be located on
State-owned land; other States may elect to follow this precedent.
There are compelling reasons for the use of public lands for
hazardous waste disposal sites. The need for long term care of
disposal sites and the potential problems associated with pritate
sector ownership of such sites have been discussed previously.
Publicly owned disposal sites could be leased to private operating
firms, but legal title would remain with the governmental body.
Use of Federal or State lands for privately operated hazardous
waste processing or disposal sites is one means of reducing the
capital cost and risk of private sector investment while reducing
environmental risk as well. Conceivably, some form of government
Influence over user charges could be a condition of the lease, In
order to avoid potential monopolistic b havior on the part of the
lessee. The initial cost to government of these measures would be
minimal; however, government maintenance of disposal sites may be
necessary If the lessee defaults.
Government Ownership and Operation of Facilities . This option provides
maximum control over the economic and environmental aspects of
hazardous waste management. The issues of potential monopolistic
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behavior (and consequent unreasonably high user charges) and long
term care of hazardous waste disposal sites could be circumvented.
Environmentally sound construction and operation of processing and
disposal facilities could be assured, but would be dependent on public
budgets for implementation. Resource recovery could be mandated.
Public land suitable for hazardous waste processing and disposal
sites exists In the western States but may not be available in the
eastern States. If government ownership and operation of facilities
is mandated by Congress, the government may have to purchase private
lands for this purpose. The potential for adverse public reaction
would be present.
The government does operate some hazardous waste treatment,
storage, and disposal facilities now, but these are generally limited
to handling wastes generated by government agencies. There Is no obvious
advantage of government operation of facilities intended to treat and
dispose of hazardous wastes originating in the private sector. In
fact, under government operation, there could be a tendency for selection
of more expensive technology than is actually required and less
incentive for efficient, low cost operation.
This option represents, of course, the maximum cost to government
of those considered here. If use of government owned and operated
facilities is mandated, capital and operating costs of processing
plants can be recovered through user charges. Some subsidy of disposal
operations is likely, however, since security and surveillance of
disposal sites is required in perpetuity.
Suninary
Given a hazardous waste regulatory program, issues of implementation
of a non-radioactive hazardous waste management system hinge on the
incentives for and inherent problems of private sector response, and
the appropriate role of government. Past experience with air and water
environmental regulation over industrial processes indicates that the
private sector will Invest in pollution control facilities if regu-
lations are vigorously enforced. EPA anticipates that similar private
sector Investment In hazardous waste processing facilities will be
forthcoming If a regulatory program is legislated and enforced. There
Is no real need for massive government intervention or Investment In
such facilities. The makeup of a hazardous waste processing system
fully prescribed by free market forces is difficult to predict, however.
The storage and ultimate disposal of hazardous residues presents
a significant problem of basically different character since the
private sector Is not well suited to a role of long term care of
disposal sites.
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Options for government action to mitigate this problem include (1) making
new or existing Federal- and State-owned and operated disposal sites
available to private industry, (2) leasing Federal or State lands to the
private sector, subject to a performance bonding system, and (3) private
ownership and operation of storage and disposal sites subject to strict
Federal or State controls. The optimum control scheme will depend upon
the nature of the regulatory program, but Federal or State control of
storage and land disposal sites Is clearly implied in any case.
On balance, EPA believes that, with the possible exception noted
above, the preferred approach to system implementation is to allow
the private sector system to evolve under appropriate regulatory controls,
to monitor closely this evolution, and to take remedial governmental
action If necessary in the future.
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Section 5
FINDINGS AND RECOMMENDATIONS
Findings
Under the authority of Section 212 of the Solid Waste Disposal Act
(as amended), the Environmental Protection Agency has carried out a
study of the hazardous waste management practices of industrial, govern-
ment, and other institutions in the United States. The key findings of
this study are presented in this section.
. ..Current management practices have adverse effects . Hazardous
waste management practices in the United States are generally inade-
quate. With some exceptions, wastes are disposed of on the land without
adequate controls and safeguards. This situation results in actual and
potential damage to the environment and endangers public health and
safety.
. ..Causes are economics and absence of legislative control . The
causes of inadequate hazardous waste management are two-fold. First,
costs of treating such wastes for hazard elimination and of disposing
of them in a controlled manner are high. Second, legislation which
mandates adequate treatment and disposal of such wastes is absent or
limited in scope. The consequence is that generators of hazardous wastes
can use l v-cost but environmentally unacceptable methods of handling
these residues.
. ..Authorities for radioactive wastes are adequate . Under the
authority of The Atomic Energy Act of 1954, as amended, the management
of radioactive wastes is placed under control. While the actual
implementation of the act may be improved, the legislative tools for
accomplishing such an end exist.
. ..Air and water pollution control authorities are adequate . The
Clean Air A t of 1970 and The Feder ãrWater Pô1lutiö Control Act of
1972 provide the necessary authorities for the regulation of the
emission of hazardous compounds and materials to the air and to surface
waters from point sources.
. ..Legislative controls over hazardous waste land disposal are
inadequate . The legislative authorities available for the control
of hazardous waste deposition on land--and the consequent migration
of such wastes into the air and water media from land--are not sufficient
to result in properly controlled disposal. This legislative gap
literally invites the use of land as the ultimate sink for materials
removed from air and water.
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. ..Land protection regulation is needed . In order to close the
last available uncontrolled sink for the dumping of hazardous waste
materials and thus to safeguard the public and the environment, it is
necessary to place legislative control over the disposal of hazardous
wastes. In the absence of such control, cost considerations and the
competitive posture of most generators of waste will continue to result
in dangerous and harmful practices with both short range and long term
adverse consequences.
• . . The technology for hazardous waste man g,ement generally is
adequate . A wide array of treatment and disposal options is available
for management of most hazardous wastes. The technology is in use today,
but the use is not widespread because of economic barriers in the absence
of legislation. Transfer and adaptation of existing technology to
hazardous waste management may be necessary in some cases. Treatment
technology for some hazardous wastes is not available (e.g., arsenic
trioxide, arsenites and arsenates of copper, lead, sodium, zinc, and
potassium). Additional research and development is required as the
national program evolves. However, safe and controlled storage of such
wastes Is possible now until treatment and disposal technology is
developed.
. ..A private hazardous waste management industry exists . A small
service industry has emerged in the last d ade offering waste treatment
services to industry and other institutions. This industry is operating
below capacity because its services are high in cost relative to other
disposal options open to generators. The industry is judged capable of
expanding over time to accept most the Nation’s hazardous wastes.
. ..Hazardous waste management system costs are significant . Estimates
made by EPA indicate that investments of about $940 million and operating
costs (including capital recovery) of about $620 million per year will be
required to Implement a nationwide hazardous waste management system which
combines on-site (point of generation) treatment of some wastes, off-site
(central facility) treatment for hazard elimination and recovery, and
secure land disposal of residues which remain hazardous after treatment.
. ..Theprivate sector appears capable of responding to a regulatory
program . Indications are that private capital will be available for the
creation of capacity and that generators of waste will be able to bear
the costs of management under new and more exacting rules. Private sector
response to a demand created by a regulatory program cannot be well
defined, however, and the characteristics of the resulting hazardous waste
management system cannot be definitely prescribed. Uncertainties inherent
In a private sector system include
- availability of capital for facility construction and operation
In a timely manner for all regions of the Nation,
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- adequacy of facility locations relative to waste generators such
as to minimize environmental hazard and maximize use,
- reasonableness of facility use charges in relation to cost of
services,
- long term care of hazardous waste storage and disposal facilities
i.e., that such facilities will be adequately secured for the
life of the waste, irrespective of economic pressures on private
site operators.
. ..Several alternatives for government action are available if such
actions are subsequently determined to be required . If capital flow were
very slow and adverse environmental effects were resulting from the
investment rate, financial assistance is possible In indirect forms such
as loans, loan guarantees or investment credits, or direct forms such as
construction grants. If facility location or user charge problems arose,
the Government could impose a franchise system with territorial limits
and user charge rate controls. Long term care of hazardous waste storage
and disposal facilities could be assured by mandating use of Federal or
State land for such facilities.
Reconinendati ons
Based on the above, It is reconr ended that...
Congress enact National legislation mandatinç
safe and environmentally sound hazardous waste
management .
The Environmental Protection Agency has proposed such legislation to
Congress, embodying the conclusions of studies carried out under Section 212
of the Solid Waste Disposal Act.
The proposed Hazardous Waste Management Act of 1973 calls for authority
to regulate the treatment and disposal of hazardous wastes. A copy of the
proposed Act is presented in Appendix G. The key provisions of the proposed
legislation are the following:
(1) Authority to designate hazardous wastes by EPA.
(2) AuthorIty to regulate treatment/disposal of selected waste
categories by the Federal Government at the discretion of the
Administrator of the Environmental Protection Agency.
(3) Authority for the setting of Federal treatment/disposal standards
for designated waste categories.
(4) State Implementation of the regulatory program subject to
Federal standards in most cases.
(5) Authority for coordination and conduct of research, surveys,
development and public education.
EPA believes that no further Government intervention is appropriate
at this time. It is EPA’s Intention to carry on its studies and analyses;
and EPA may make further recoiiinendatlons based on these continuing analyses.
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REFERENCES
1. Swift, W. H. Feasibility study for development of a system of
hazardous waste national disposal sites. v.1. U.S. Environmental
Protection Agency Contract No. 68—06—0762. [ Richiand, Wash.],
Battelle Memorial Institute, Mar. 1, 1973. p.”— 63 .
(Unpublished data.)
2. U.S. Congress. Marine Protection, Research, and Sanctuaries Act
of 1972. Public Law 92—532, 92d Cong., H.R.9727. Washington,
Oct. 23, 1972. 12 p.
3. Smith, D. B., and R. P. Brown. Ocean disposal of barge—delivered
liquid and solid wastes from U.S. coastal cities. Washington,
U.S. Government Printing Office, 1971. p. 10 .
4. Swift, Feasibility study for development of a system of
hazardous waste national disposal sites, v.2, p.IV—D—1 to IV—
D—4 2 *
5. Ottinger, R. S. Recommended methods of reduction, neutralization,
recovery, or disposal of hazardous waste. v.1. U.S. Environmental
Protection Agency Contract No. 68—03—0089. [ Redondo Beach, Calif.],
TRW Systems Group, Inc., June 1973. (Unpublished data.)
6. Booz, Allen Applied Research, Inc. A study of hazardous waste
materials, hazardous effects and disposal methods. U.S. Environmental
Protection Agency Contract No. 68—03—0032. [ Bethesda, Md.], June 30,
1972. 3 v.
7. Ottinger, Recommended methods of reduction, neutralization, recovery,
or disposal of hazardous waste, 15 v.
8. Lackey, L. L., S. R. Steward, and T. 0. Jacobs. Public attitudes
toward hazardous waste disposal facilities. U.S. Environmental
Protection Agency Contract No. 68—03—0156. [ Colunibus, Ga.], Human
Resources Research Organization, Feb. 1973. (Unpublished data.)
9. Funkhouser, J. T. Alternatives to the management of hazardous wastes
at national disposal sites. U.S. Environmental Protection Agency
Contract No. 68—01—0556. [ Cambridge, Mass.], Arthur D. Little, Inc.,
May 1973. 2 v. (Unpublished data.)
1.0. Swift, Feasibility study for development of a system of hazardous waste
national disposal sites, 2 v.
11. christensen, H. E.., ed. Toxic substances annual list, 1971. National
Institute for Occupational Safety and Health Publication DHEW
(HSM) 72—10260. Washington, U.S. Government Printing Office,
1971. 512 p.
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12. Council on Environmental Quality. Toxic substances Washington,
U.S. Government Printing Office, Apr. 1971. p. 2 .
13. U.S. Congress. Proposed Hazardous Waste Management Act of 1973.
93d Cong., 1st sess., U.S. Senate, S.1086, introduced Mar. 6,
1973, U.S. House of Representatives, H.R.4873, introduced Feb.
27, 1973. [ Washington], U.S. Environmental Protection Agency.
25 p.
14. Swift, Feasibility study for the development of a system of hazardous
waste national disposal sites, v.1, p.”— 2 .
15. Environmental quality; the first annual report of the Council on
Environmental Quality together with the President’s message to
Congress. Washington, U.S. Government Printing Office, Aug. 1970.
p. 107.
16. Council on Environmental Quality, Toxic substances, p. 2 .
17. Council on Environmental Quality, Toxic substances, p. 2 .
18. Mahier, H. R., and E. H. Cordes. Biological chemistry. New York,
Harper & Row, 1966. 872 p.
19. Council on Environmental Quality, Toxic substances, p.2.
20. Johnson, 0. Pesticides ‘72. Chemical Week , 11O(25):33—48, 53—66,
June 21, 1972; 1ll(4):17—46, July 26, 1972.
21. Jansen, L. L. Estimate of container number by size, type, and
formulations involved. In Proceedings; National Working
Conference on Pesticides, U.S. Department of Agriculture,
Beltsville, Nd., June 30—July 1, 1970. p. 27 — 30 . [ Distributed
by National Technical Information Service, Springfield, Va. as
PB 197 145.1
22. Jansen, Estimate of container number by size, type, and formulations
involved, p.27—28.
23. Ottinger, Recommended methods of reduction, neutralization, recovery,
or disposal of hazardous waste, v.14, p. 199 .
24. Swift, Fesibility study for development of a system of hazardous
waste national disposal sites, v.1, p.V—l to V—218.
25. Booz, Allen Applied Research, Inc., A study of hazardous waste
materials, hazardous effects and disposal methods, v.1, p.A—II—1
to A—II—22.
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26. Proceedings; American Hospital Association [ Institute on Hospital
Solid Waste Management], Chicago, May 18—20, 1972. v.3.
27. Personal communication. Chemical Biological Warfare Office, U.S.
Army Material Command, Washington.
28. Council on Environmental Quality, Toxic substances, p.8.
29. U.S. Tariff Commission. Synthetic organic chemicals; United States
production and sales, [ 1954—19701. Washington, U.S. Government
Printing Office. [ 15 v.}
30. Commissioner Ray stresses positive understanding. Hanford News
( Hanford, Wash.) , p.5, Oct. 27, 1972.
31. Ottinger, Recommended methods of reduction, neutralization,
recovery, or disposal of hazardous waste, v.2, p. 5 .
32. Council on Environmental Quality, Toxic substances, p.2.
33. Council on Environmental Quality, Toxic substances, p.9.
34. Council on Environmental Quality, Toxic substances, p.9.
35. Committee on Toxicology. Toxicological reports. Washington,
National Academy of Sciences—National Research Council, 1971.
2 l9p.
36. Funkhouser, Alternatives to the management of hazardous wastes at
national disposal sites, v.1, p. 3 . 5 . 1 .
37. Swift, Feasibility study for a system of hazardous waste national
disposal sites, v.1, p.IV—ll.
38. Swift, Feasibility study for a system of hazardous waste national
disposal sites, v.1, p.IV—l2.
39. Swift, Feasibility study for a system of hazardous waste national
disposal sites, v.1, p.IV—12.
40. Swift, Feasibility study for a system of hazardous waste national
disposal sites, v.1, p. 1 — 41 — 42 .
41. Ottinger, Recommended methods of reduction, neutralization, recovery,
or disposal of hazardous waste, v.1, p. 135 — 298 .
42. Funkhouser, Alternatives to the management of hazardous wastes at
national disposal sites, v.1, p. 3 . 24 — 3 . 33 .
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43. U.s. Congress. Resource Recovery Act of 1970. Public Law 91—512,
91st Cong., H.R.11833. Washington, Oct. 26, 1970. [ 9 p.]
44. U.S. Congress. Atomic Energy Act of 1954. Public Law 703, 83d
Cong., H.R.9757. Washington, Aug. 30, 1954. [ 41 p.]
45. United States Code, Title 18, chap.39. Explosives and other
dangerous articles. sec.83l—5. Washington, U.S. Government
Printing Office, 1971.
46. U.S. Congress. [ Federal Railroad Safety and Hazardous Materials
Control] Act. Title 111——Hazardous materials control. sec.302.
Public Law 91—458, 91st Cong., S.l933. Washington, Oct. 16, 1970.
fp. 7 .] (United States Code, Title 46, sec.1761—2.)
47. U.S. Congress. Federal Aviation Act of 1958. Title VT——Safety
regulations of civil aeronautics. sec.601. Public Law 85—726,
85th Cong., S.3880. Washington, Aug. 23, 1958. [ p. 45 — 46 .]
(United States Code, Title 49, sec.1421.)
48. United States Code, Title 46, chap.7. Carriage of explosives or
dangerous substances. sec.170. Washington, U.S. Government
Printing Office, 1971.
49. U.s. Congress. Federal Hazardous Substances Labeling Act. sec.l7.
Public Law 86—613, 86th Cong., S.1283. Washington, July 12,
1960. [ p.9.] (United States Code, Title 15, sec.l261 et seq.)
50. U.S. Congress. Federal Environmental Pesticide Control Act of
1972. sec.19. Disposal and transportation. Public Law 92—516,
92d Cong., H.R.l0729. Washington, Oct. 21, 1972. p. 2 3— 24 .
51. Federal Environmental Pesticide Control Act, sec.19(a), p. 2 3— 24 .
52. U.S. Congress. Marine Protection, Research, and Sanctuaries Act of
1972. Title I——Ocean dumping. sec.lOl. Public Law 92—532, 92d
Cong., H.R.9727. Washington, Oct. 23, 1972. p. 2 .
53. Marine Protection, Research, and Sanctuaries Act, Title I——Ocean
dumping, sec.l02(a), p.3.
54. U.S. Congress. Clean Air Amendments of 1970. Public Law 91—604,
91st Cong., 1I.R.17255. Washington, Dec. 31, 1970. [ 32 p.]
(United States Code, Title 42, sec.1857 et seq.)
55. U.S. Congress. Federal Water Pollution Control Act Amendments of
1972. Public Law 92—500, 92d Cong., S.2770. Washington, Oct. 18,
1972. 89 p.
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56. U.s. Congress. Poison Prevention Packaging Act of 1970. sec.3.
Public Law 91—601, 91st Cong., S.2162. Washington, Dec. 30,
1970. [ p.1-2.]
57. U.S. Congress. [ Crab Orchard National Wildlife Refuge, Ill.
Legislative Jurisdiction by U.S. Adjustment] Act. Public Law
90—339, 90th Cong., S.2452. Washington, June 15, 1968. [ p. 1 .]
(United States Code, Title 21, sec.l857 et seq.)
58. U.S. Congress. National Environmental Policy Act of 1969. Public
Law 91—190, 91st Cong., S.1075. Washington, Jan.1, 1970. [ 5 p.]
(United States Code, Title 42, sec.4321 et seq.)
59. U.S. Congress. [ Armed Forces Appropriation Authorization, 1970] Act.
Public Law 91—121, 91st Cong., S.2546. Washington, Nov. 19, 1969.
[ 10 p.]; [ Armed Forces Appropriation Authorization, 1971.] Public
Law 91—441, 91st Cong., H.R.17123. Washington, Oct. 7, 1970.
[ 10 p.] (United States Code, Title 50, sec.l5ll—l8.)
60. U.S. Congress. Coastal Zone Management Act of 1972. Public Law
92—583, 92d Cong., S.3507. Washington, Oct. 27, 1972. 10 p.
61. U.S. Congress. Occupational Safety and Health Act of 1970. sec.6
(b)(5). Public Law 91—596, 91st Cong., S.2193. Washington, Dec.
29, 1970. [ p. 16 .]
62. Swift, Feasibility study for a system of hazardous waste national
disposal sites, v.1, p.1X32—1X33.
63. U.S. Congress. Clean Air Amendments of 1970. Public Law 91—604,
91st Cong., H.R.l7255. Washington, Dec. 31, 1970. [ 32 p.]
(United States Code, Title 42, sec.1857 et seq.)
64. U.S. Congress. Federal Water Pollution Control Act Amendments of
1972. Public Law 92—500, 92d Cong., S.2770. Washington, Oct.
18, 1972. 89 P.
65. Reitze, A. W., Jr. Tax incentives don’t stop pollution. In
Environmental Law. Spring of 1972 ed. Washington, North American
International.
66. Kennecott Copper v. EPA, U.S. App. D.C., _F. 2nd , 3 ERC 1682,
(Feb. 18, 1972).
67. Anaconda Company v. Ruckelshaus, D.C. Colorado, F. Supp._,
4 ERC 1817, (Dec. 19, 1972).
68. International Harvester Company v. Ruckeishaus, U.S. App. D.C.,
F. 2nd, 4 ERC 2041, (Feb. 10, 1973).
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69. U.S. Congress. Poison Prevention Packaging Act of 1970. sec.112
(b)(l)(B). Public Law 91—601, 91st Cong., S.2162. Washington,
Dec. 30, 1970. [ p.1 6 .]
70. U.S. Congress. Federal Water Pollution Control Act Amendments of
1972. Title V——General provisions. sec.502(14). Public Law
92—500, 91st Cong., S.2770. Washington, Oct. 18, 1972. p. 72 .
71. Federal Water Pollution Control Act, Title Ill——Standards and
Enforcement, sec..304(c)(2)(D), Public Law 92—500, p. 36 — 37 .
72. Federal Water Pollution Control Act, Title III, sec.306(a)(1),
p. 39—40.
73. Federal Water Pollution Control Act, Title III, sec.307(a)(4)(6),
p .42.
74. Federal Water Pollution Control Act, Title III, sec.31l(b)(2)(A),
p.48.
75. Federal Water Pollution Control Act, Title III, sec.311(b)(3), p.49.
76. Reitze, Tax incentives don’t stop pollution, Environmental law,
chap.3d and 4g.
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Appendix A
IMPACT OF IMPROPER HAZARDOUS WASTE MANAGEMENT
ON THE ENVIRONMENT
Improper management of hazardous materials or wastes is manifested
in numerous ways. Waste discharges into surface waters can decimate
aquatic plant and animal life. Contamination of land and/or ground waters
can result from improper storage and handling techniques, accidents in
transport, or indiscriminate disposal acts.
A few of the many cases documented by EPA which illustrate hazardous
waste mismanagement are listed categorically in the following compilation.
Most of these examples are water pollution related because there ? ave
been more monitoring and enforcement actions in this area.
Category I - Waste Discharge Hazards
(1) Improper Arsenic Disposal . Because of the lack of treatment and
recovery facilities, arsenic waste materials generally are disposed of by
burial. This practice presents future hazards since the material is not
rendered harmless.
As a result of arsenic burial 30 years ago on agricultural land in
Perham, Minnesota, several people who recently consumed water contaminated
by the deposit were hospitalized. The water came from a well that was
drilled near this 30 year old deposit of arsenic material. Attempts to
correct this contamination problem are now being studied. Proposed methods
of approach include (1) excavating the deposit and contaminated soil and
diluting it by spreading it on adjacent unused farm land, (2) covering
the deposit site with a bituminous or concrete apron to prevent ground
water leaching, (3) covering the deposit temporarily and excavating the
soil for use as ballast in future highway construction in the area, and
(4) excavating the material and placing it in a registered landfill.
None of these methods is particularly acceptable since the hazardous
property of the material is not permanently eradicated, but they at least
protect the public health and safety in the short run.
(2) Lead Waste Hazard . Annual production of organic lead waste from
manufacturing processes for alkyl lead in the San Francisco Bay area
amounts to 50 (45.4 metric tons) tons. This waste was previously disposed
of in ponds at one industrial waste disposal site. Attempts to process
this waste for recovery resulted in alkyl lead intoxication of plant
employees, in one instance, and in another instance not only were plant
employees affected, but also employees of firms in the surrounding area
were exposed to an airborne alkyl lead vapor hazard. Toll collectors on
a bridge along the truck route to the plant became ill from escaping vapors
from transport trucks. Currently, the manufacturers which generate organic
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lead waste are storing this material in holding basins at the plants
pending development of an acceptable recovery process.
(3) Cyanide, Phenol Disposal . A firm in Houston, Texas, as early as
1968 was made aware that its practice of discharging such hazardous
waste as cyanides (25.40 ibs./day, or 11.5 kilograms/day), phenols (2.1
lbs./day, or 0.954 kilograns/day), sulfides, and aim onia into the Houston
ship channel was creating severe environmental debilitation. The toxic
wastes in question are derived from the cleaning of blast furnace gas
from coke plants. Based on expert testimony, levels as low as 0.05 mg/i
of cyanide effluent are known to be lethal to shrimp and small fish of
the species found in the Galveston Bay area.
Alternative disposal methods involving deep well injection were
recommended by the firm and the Texas Water Quality Board. EPA rejected
this proposal and the firm in question was enjoined by the courts to
cease and desist discharging these wastes into the ship channel.
Sitsequently, the courts have ruled in favor of EPA that deep well injection
of these wastes is not an environmentally acceptable disposal method at
this site.
(4) Arsenic Contamination . A chemical company in Harris County, Texas,
that produces insecticides, weed killers, and similar products containing
arsenic has been involved in litigation over the discharge of arsenic
waste onto the land and adjacent waters. Charges indicate that waste
containing excessive arsenic was discharged into, or adjacent to, Vince
Bayou causing arsenic-laden water drainage into public waters. This
company and its predecessor have a long history of plant operation at
this site. Earlier, waste disposal was accomplished by dumping the waste
solids in open pits and ditches on the company’s property. This practice
was abandoned in 1967 in favor of a proposed recycling process. However,
as of August 1971, actions were taken on behalf of the county to enjoin
manufacturing operations at the plant because of alleged excessive arsenic
discharge into the public waters. No other information is available
regarding the current status of court actions or disposal practices.
(5) Insecticide Dumping .
(a) In mid-1970, an applicator rinsed and cleaned a truck rig after
dumping unused Endrin into the Cuivre River at Mosco Mills, Missouri.
This act resulted in the killing of an estimated 100,000 fish and the
river was closed to fishing for one year by the Missouri Game and Fish
Commission.
(b) In mid-1972, a chemical manufacturing company in Waterloo, Iowa,
burned technical mevinphos (phosdrin), resulting in gross contamination
to the plant area. Approximately 2,000 pounds (908 kilograms) of previously
packaged material were dumped and left for disposal. After discussion
with EPA Region VII office personnel and appropriate Iowa agencies, the
area was neutralized with alkali and certain of the materials were
repackaged for disposal by a private hazardous waste disposal firm in
Sheffield, Illinois.
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(6) Trace Phenol Discharge . During 1970, the Kansas City, Missouri,
water supply contained objectionable tastes and odors due to a phenolic
content. It was alleged, and subsequent investigation indicated, that
fiberglass wastes dumped along the river bank upstream was the source
of the tastes and odors. The waste was coated with phenol and was
possibly being washed into the river. Action was taken to have the dump
closed and sealed.
(7) Fatality Caused by Discharge of Hydrocarbon Gases Into River . In
July 1969, an Assistant Dean at the University of Southern Mississippi
died of asphyxiation while fishing in a boat in the Leaf River near
Hattiesburg, Mississippi. The victim’s boat drifted into a pocket of
propane gas that reputedly had been discharged into the river through a
gasline terminal “wash pipe” from a petroleum refinery.
(8) Cyanide Discharge . Part of the Lowry AFB Bon ing Range, located 15
miles (24.1 kilometers) east of Denver was surplused and given to Denver
as a landfill site. As of July 1972, the Lowry site was accepting, with
the exception of highly radioactive wastes, any wastes delivered without
inquiry into the contents and without keeping anything more than informal
records of quantities delivered.
Laboratorytestsof surface drainage have indicated the presence of
cyanide in ponded water downstream from the site. Significant amounts of
cyanide are discharged in pits at the disposal site, according to the
site operator. Short-lived radioactive wastes from a nearby medical
school and a hospital also are accepted at this site. These wastes are
apparently well protected, but are dumped directly into the disposal
ponds rather than being buried separately.
The Denver County Comissioners received a complaint that some
cattle had died as the result of ingesting material washed downstream
from this site. Authorities feel this occurred because of runoff caused
by an overflow of the disposal ponds into nearby Murphy Creek after a
heavy rainstorm.
(9) Arsenic Dump - Groundwater Contamination . A laboratory company in
the north central United States has been utilizing the same dump site
since 1953 for solid waste disposal. Of the total amount (500,000 cubic
feet or 14,150 cubic meters) dumped as of 1972, more than half is waste
arsenic. There are several superficial monitoring wells (10-20 feet deep
or 3.05-6.10 meters) located around the dump site. Analyses of water samples
have produced an arsenic content greater than 175 ppm. The dump site is
located above a limestone bedrock aquifer, from which 70 percent of the
nearby city’s residents obtain their drinking and crop irrigation water.
There are some indications that this water is being contaminated by
arsenic seepage through the bedrock.
(10) Poisoning of Local Water Supply . Until approximately two years prior
to June 1972, Beech Creek, Waynesboro, Tennessee, was considered pure
enough to be a source of drinking water. At that time, waste polychlorinated
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biphenyls (PCB) from a nearby plant began to be deposited in the Waynesboro
city dump site. Dumping continued until April 1972. Apparently, the
waste, upon being off-loaded at the dump, was pushed into a spring branch
that rises under the dump and then empties into Beech Creek. Shortly
after depositing of such wastes began, an oily substance appeared in
the Beech Creek waters. Dead fish, crawfish, and waterdogs were found
and supported wildlife also was being affected (e.g., two raccoons
were found dead). Beech Creek had been used for watering stock, fishing,
drinking water, and recreation for decades. Presently, the creek seems
to be affected for at least 10 miles (16.09 kilometers) from its source
and the pollution is moving steadily downstream to the Tennessee River.
Health officials have advised that the Creek should be fenced off to
prevent cattle from drinking the water.
Category II _ - _ Mismanagement of Waste Materials
In the presence of locally imposed air and water effluent restrictionsf
prohibitions, industrial concerns attempt to manage disposal problems
by storage, stockpiling, and/or lagooning. In many instances, the waste
quantities become excessive and environmental perils evolve as a result
of leaching during flooding or rupturing of storage lagoons. Instances
of this type of waste management problem which have been reported are
shown in the following:
(1) Fish Kills (one of many examples) . On June 10, 1967, a dike containing
an alkaline waste lagoon for a steam generating plant at Carbo, Virginia,
collapsed and released approximately 400 acre-feet (493,400 cubic meters)
of fly ash waste into the Clinch River. The resulting contaminant slug
moved at a rate of one mile/hr. (1.6 kilometers/hour) for several days
until it reached Norris Lake in Tennessee; whereupon, it is estimated
to have killed 216,200 fish. All food organisms in the 4 mile (6.43
kilometers) stretch of river immediately below Carbo were completely
eliminated. The practice of waste disposal by lagooning is a notoriously
inadequate method which lends itself to negligence and subsequent mishaps.
(2) Phosphate Slime Spill . On December 7, 1971, at a chemical plant site
in Fort Meade, Florida, a portion of a dike forming a waste pond ruptured
releasing an estimated two billion gallons (7.58 billion liters) of slime
con osed of phosphatic clays and insoluble halides into Whidden Creek.
Flow patterns of the creek led to subsequent contamination of Peace River
and the estuarine area of Charlotte Harbor. The water of Charlotte Harbor
took on a thick milky white appearance. Along the river, signs of life
were diminished, dead fish were sighted and normal surface fish activity
was absent. No living organisms were found in Whidden Creek downstream
of the spill or in Peace River at a point eight miles downstream of Whidden
Creek. Clam and crab gills were coated with the milky substance and in
general all benthic aquatic life was affected in some way.
(3) Mismanagement of Heterogeneous Hazardous Waste . A firm engaged in the
disposal of spent chemicals generated in the Beaumont-Houston area ran
into considerable opposition in Texas and subsequently transferred its
disposal operations to Louisiana. In October, 1972, this firm was storing
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and disposing toxic chemicals at two Louisiana locations: De Ridder and
De Quincy. At the De Ridder site, several thousand drums of waste (both
metal- and cardboard-type, some with lids and some without) were piled
up at the end of an airport runway apron within a pine tree seed orchard.
Many of the drums were popping their lids and leaking, and visible vapors
were emanating from the area. The pine trees beside the storage area
had died. At the same time, the firm was preparing to bury hundreds of
drums of hazardous wastes at the De Quincy location, which is considered
by EPA to be hydrogeologically unsuitable for such land disposal. Finally,
court action enjoined this firm from using the De Ridder and De Quincy
sites; however, the company has just moved its disposal operations near
Villa Platte in Evangeline Parish, where the same problems exist.
(4) Arsenic Waste Mishap . Since August 1968, a commercial laboratory in
Myerstown, Pennsylvania, has disposed of its arsenic waste by surface
storage within the plant area. (Form of waste materials not known.)
This practice apparently has led to contamination of the ground and
subsequent migrations into groundwaters via leaching, ionic migration
actions, etc., abetted by the geologic and edaphic character of the plant
site. In order to meet discharge requirements and/or eliminate the
waste hazard, the company has had to design and construct a system of
recovery wells to collect the arsenic effluent from ground waters in the
area. Recovered arsenic and current arsenic waste (previously stored on
the land) are now retained in storage lagoons. Presumably, the sludge
from these lagoons is periodically reclaimed in some way. Lagoons of
this type are generally not well attended and frequently result in
environmental catastrophes. (As evidenced under case 1 above.)
(5) Contaminated Grain .
(a) Grant County, Washington . In 1972, mercury-treated grain was found
at the Wilson Creek Dump by an unsuspecting farmer. He hauled it to his
farm for livestock feed. The episode was discovered just before the
farmer planned to utilize the grain.
(b) Albuquerque, New Mexico . Three children in a family became seriously
ill, in 1970, after eating a pig which had been fed corn treated with a
mercury compound. Local health officials found several bags of similarly
treated corn in the community dump.
(6) Radioactive Waste; Steven County, Washington . Low level radioactive
waste is lying exposed on about 10 acres (4.05 hectares) of ground and is
subject to wind erosion. The waste comes from an old uranium processing
mill. County and State officials are concerned because, although it is
of low radioactivity.level, it is the same type that caused the public
controversy at Grand Junction, Colorado.
(7) Waste Stockpiling Hazard; King County, Washington .
(a) All types of waste chemicals have been dumped into the old Dodgers
Nunter Five Coal Mine shaft for years. Much of this practice has stopped
but sneak violations still occur.
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(b) Expended pesticides have been stored in old wooden buildings in
the area that are very susceptible to fire. Several fires have occurred.
In addition, large numbers of pesticide containers have been stacked at
open dumps.
(8) Chlorine Holdin Pond Breach . A holding pond and tanks at a chemical
manufacturing plant in Saltville, Virginia failed,spilling chlorine,
hypochiorites and amonia into the North Fork Holston River. River
water samples showed concentration levels at 0.5 ppm hypochiorite, and
17.0 ppm of fixed aninonia. Dead fish were sighted along the path of the
flow in the river.
(9) Malpractice Hazard; Bingham County, Idaho . Several drums of a 15 year
old chemical used for soil sterilization were discovered in the warehouse
of the weed control agency. It was taken to a remote area where it was
exploded with a rifle blast. Had it been disturbed only slightly while
in storage, several people would have been killed.
(10) Explosive Waste; Kitsap County, Washington . Operations at a Naval
Amunition Depot involved washing RDX (a high explosive) out of shells
from 1955-1968, and the resulting wash water went into a dump. In
routine monitoring of wells in the area, the RDX was found in the groundwater
and in several cases the concentrations exceed the health tolerance level
of 1 ppm.
(11) Unidentified Toxic Wastes . A disposal company undertook to dispose
some drums containing unidentified toxic residues. Instead of properly
disposing of this material, the disposal company dropped these drums off
at a dump located in Cabayon, Riverside County, California. Later, during
a heavy flood, the drums were unearthed, gave off poisonous gases, and
contaminated the water. Steps were taken to properly dispose of the
unearthed drums.
(12) Container Reclamation . At a drum reclaiming plant in northern
California, 15 men were poisoned by gases given off from the drums. It
is presumed that this incident occurred because of inadequate storage
procedures by the company involved.
(13) Stockpiling of Hazardous Waste (Great Britain) Several sheep and
cattle and a foxhound dTed, and many cattle became seriously affected,
on two farms close to a factory producing rodenticides and pesticides.
The drainage from the factory led into a succession of ponds to which
the animals had unrestricted access, and from which they are therefore
likely to have driu k. Investigations showed that a field on the site
was a dumping ground for large metal drums and canisters, many of which
had rusted away and their contents were seeping into the ground. Residues
from the manufacture of fluoroacetamide were dumped on the site, and
percolated into the drainage ditches leading to the farm ponds. Veterinary
*Case illustrates the similarity of problems that exist in highly
industrialized nations.
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evidence indicated the assimilation of fluoroacetamide compatible with
the animals having drunk contaminated water. Ditches and ponds were
dredged and the sludge deposited on a site behind the factory. All sludges
and contaminated soil were subsequently excavated, mixed with cement,
put into steel drums capped with bitumen, and dumped at sea. The presence
of fluoroacetamide in the soil and associated water samples persisted
at very low, but significant levels, and thus delayed the resumption of
normal farming for nearly two years.
(14) Pesticides in Abandoned Factory . In the sumer of 1972, approximately
1,000 pounds (454 kilograms) of arsenic-containing pesticidewere discovered
in an abandoned factory building in Camden County, New Jersey. The building
used to belong to a leather tannery that had discontinued its operations.
(15) Ground Water Contamination by Chromium- and Zinc-containing Sludge .
An automobile manufacturing company in the New York area is regularly
disposing of tank truck quantities of chromium- and zinc-containing
sludge through a contract with a trucking firm, that in turn has a
subcontract with the owner of a private dump. The sludge is dumped in a
swampy area, resulting in contamination of the ground water. The sludge
constitutes a waste residue of the automobile manufacturer’s paint priming
operati ons.
(16) Disposal of Chromium Ore Residues . A major chemical company is
currently depositing large quantities of chromium ore residues on its
own property in a major city on the East Coast. These chromium ore
residues are piled up in the open, causing probable contamination of
the ground water by leaching into the soil.
(17) Dumping of Cadmium-containing Effluents into the Hudson River . A
battery plant in New York State for years was dumping large amounts of
cadmium-containing effluents into the Hudson River. The sediment resulting
from the plant’s effluents contained about 100,000 ppm of cadmium. The
firm now has agreed to deposit these toxic sediments in a specially
insulated lagoon.
(18) Pesticide Poisoni g . On July 3, 1972, a 2 1/2 year old child in
Hughes, Arkansas, became ill after playing among a pile of fifty-five
gallon (208 liter) drums. He was admitted to the hospital suffering from
symptoms of organophosphate poisoning. The drums were located approximately
fifty feet (15 meters) from the parents’ front door on city property.
The city had procured the drums from an aerial applicator to be used as
trash containers. The residents were urged to pick up a drum in order
to expedite trash collection. It has been determined that these drums
contained various pesticides, including methyl parathion, ethyl parathion,
toxaphene, DDT, and others. The containers were in various states of
deterioration, and enough concentrate was in evidence to intoxicate a
child or anyone Olse who was unaware of the danger.
(19) Improper Disposal of Aldrin-treated Seed and Containers . On July 9, 1969,
in Patterson, Louisiana, the owner of a farm noticed several pigs running
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out of a cane field; some of the animals appeared to be undergoing
convulsions. It appears that aidrin-treated seed and containers had been
dumped on the land in a field and that the pigs, running loose had
encountered this material. Eleven of the pigs died. Analysis of rumen
contents showed 230.7 ppm aidrin and 1.13 ppm dieldriri.
(20) roper Pesticide Container Disposal . In May 1969, in Jerome, Idaho,
Di-Syston was incorporated into the soil in a potato field. The “empty”
paper bags were left in the field, and the wind blew them into the adjacent
pasture. Fourteen head of cattle died, some with convulsions, after
licking the bags. Blood samples showed .0246 ppm Di-Syston.
(21) Ocean Dumping of Chemical Waste . The Houston Post reported in December
1971 that large quantities of barrels containing chemical wastes had turned
up in shrimpers’ nets in the Gulf of Mexico approximately 40 miles (64.3
kilometers) off the Texas coastline. Aside from physical damages to nets
and equipment,the chemical wastes caused skin burning and eye irritation
among exposed shrimper crewmen. Recovered barrels reportedly bore the
names of two Houston-area plants--both of whom apparently had used a
disposal contractor specializing in deep sea disposal operations.
Category III - Radioactive Waste Disposal
(1) National Reactor esting Station . In October 1968, the Idaho Department
of Health and the former Federal Water Quality Administration made an
examination of the waste treatment and disposal practices at the AEC National
Reactor Testing Station (NRTS) near Idaho Falls, Idaho. There were three
types of plant wastes being generated: radioactive wastes, chemical or
industrial wastes, and sanitary wastes. It was found that there were no
observation wells to monitor the effects of the burial ground on water
quality, that low-level radioactive wastes were being discharged into the
ground water, that chemical and radioactive wastes had degraded the
ground water beneath the NRTS, and that some sanitary wastes were being
discharged into the ground water supply by disposal wells.
In a report issued in April 1970, authorities recommended that the
AEC abandon the practice of burying radioactive waste above the Snake
Plain aquifer, remove the existing buried wastes to a new site remote
to the NRTS and hydrologically isolated from groundwater supplies, and
construct observation wells that are needed to monitor the behavior and
fate of the wastes.
(2) De-Comlssioning of AEC Plant . The Enrico Fermi nuclear reactor just
outsl of Detroit is closing. However, there still remains a substantial
waste management problem. The owner of the plant has set aside $4 million
for de-convnisslonlng the plant. A preliminary de-coninlssioning plan and
cost estimate have been submitted to the AEC. However, the AEC acknowledges
that costs and procedures for de-coffinissioning are still unknown, since
few nuclear plants (and never one such as Fermi) have been de. .com1 sloned,
As of this date, an answer Is still being sought to this waste disposal
problem.
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(3) Nuclear Waste Disposal , After a fire on May 11, 1969 at the Rocky
Flats plutonium production plant near Denver, Colorado, it was discovered
that since 1958 the company that operated the plant had been storing
outside on pallets fifty-five gallon drums of laden oil contaminated
with plutonium.* The drums corroded and the plutonium-contaminated oils
leaked onto the soil in the surrounding area. Soil sample radioactivity
measurements made in 1970-71-at various locations on the Rocky Flats site
indicated that the surrounding area was contaminated 100 times greater
than that due to world-wide fallout. The increase in radioactivity as
defined by the health and safety laboratory of AEC was attributed to the
plutonium leakage from the stored fifty-five gallons drums rather than
any plutonium that might have been dispersed as a result of the 1969
fire. Later the area where the plutonium contaminated laden oil was
spilled was covered with a four inch slab of asphalt and isolated by
means of a fence. The fifty-five gallon drums were moved to a nearby
building and the plutonium was salvaged from the oil. The oil was dewatered
and solidified into a grease-like consistency. Then the drums and the
solidified oil were sent to and buried at the National Reactor Testing
Station at Idaho Falls, Idaho.
* Containing measurable quantities of plutonium.
77

-------
Appendix B
HAZARDOUS WASTE STREAM DATA
Identifying and quantifying the Nation’s hazardous waste streams
proved to be especially formidable, because historically there has been
little interest in quantifying specific amounts of waste materials with
the exception of radioactive wastes.
Distribution and volume data by Bureau of Census regions were
compiled on those non—radioactive waste streams designated as hazardous
(see Table B-i). Table B-2 identifies those states geographically dis-
tributed within the nine Bureau of Census regions. The approach used is
predicated on the assumption that the hazardous properties of a waste
stream will be those of the most hazardous pure compound within that
waste stream. Using threshold levels established for the various hazardous
properties, wastes containing compounds with values more than or equal to
these thresholds are classified as hazardous. This approach takes advan-
tage of the available hazard data on pure chemicals and avoids speculation
on potential compound interactions within a waste stream. Table 8-3
serves to illustrate what types of chemical compounds in the Nation’s
waste streams could be regarded as hazards to public health and the
environment. It should be noted that Table B-3 is not an authoritative
enumeration of hazardous compounds but a sample list which will be modi-
fied on the basis of further studies.* Table B-4 identifies those radio-
active isotopes that are considered hazardous.t Detailed data sheets
describing the volumes, constituents, concentrations, hazards, disposal
techniques, and data sources for each waste stream are available in EPA
Contract No. 68-01-0762.
It is important to emphasize that while Table B—i is sufficiently
accurate for planning purposes, the indicated total national non-
radioactive hazardous waste volume of 10 million tons (9 million metric tons)
per year is not a firm number but an estimate based on currently available
information. A more accurate indication of actual waste volumes will
become available only after a comprehensive national waste inventory has
been accomplished for specific waste streams.
* Compounds on the list should not be construed as those to be regulated
under the proposed Hazardous Waste Management Act.
t From a disposal standpoint.
78

-------
Table B—i
Summary Data For Nonradioactive Waste Streams
1031 Zinc Ore Roasting Acid Wash
333 Brass Mill Wastes
1099 Cadmium Ore Extraction
3312 Coke Plant Raw Waste
331 Consolidated Steel,Plant Wastes
331 Iron Manufacturing Waste Sludge
1021 Recovered Arsenic from Refinery Flues
(Stored)
1092 Mercury Ore Extraction Wastes
3312 Stainless Steel Pickeling Liquor
333 Arsenic Trioxide from Smelting Industry
291 Copper and Lead Bearing Petroleum
Refinery Wastes
3691 Battery Manufacturing Wastes
3691 Battery Manufacturing Waste Sludge
3692 Mercury Cell Battery Wastes
3585 Refrigeration Equipment Manufacturing
Wastes
3555 Duplicating Equipment Manufacturing
Wastes
3555 Graphic Arts Photography Wastøs
(Leather Press Plates)
3555 Rotogravure Printing Plate Wastes
3231 Mirror Production Wastes
372 Aircraft Plating Wastes
40 Arsenic Wastes from Transportation
Indus try
40 Railroad Engine cleaning
Geographic Distributio
NE MA ENC WNC SA ESC WSC N M
.04 .29 .01 .25 .01 .04 .04 .19 .13
.02 .33 .31 .01 .07
.02 .33 .42 .02 .09
.05 .05 .56 .02 .12
7X10 5 (Upstate,
3 New York)
.06 .09 .04 .13 4X10
sIc t Waste Stream Title
Fraction
.02 .06 .02 .06
.02 .03 .02 .05
.03 .09 .03 .05
-- —— 1.00 ——
.050 .259 .404 .026 .068 .055 .044
—— .03 .015 .07 .005 .01 .10
.001 .102 .175 .056 .019 .031 .417
Volume (ibs/yr )
5X10
2X10
eX1. 0
5x]-0
6Xl0
4X10 (Tacoma,
Wa.)
5X10 7
2X10
8Xl O
5X1C
8 *M&W CombincI
2Xl 0
.72 .28
.067 .028
.07 .70
.160 .039
.030 .236
.117 .043
.060 .138
.013 .232
1.00
.289 .111 .103
—— .118 .117
.556 .049 .074
.408 .096 .040
.029 .056
.019 .017
.069 .086
.134
.087*
.045
.012
118
.011
.06 .19 .20 .08 .15
.105 .446 .320 .051 .019 —— .028
.09 .25 .23 .01 .28 .10 .04
.123 .158 .117 .093 .057 .013 .095
* Classified by Bureau of Census
NE = New England
MA = Mid Atlantic
ENC = East North Central
WNC = West North Central
.031
.325 .019
9X10 6
4X 10
regions.
ESC = East South Central
WSC = West South Central
W = West
M Mountain
SA = South Atlantic

-------
SIC *
Waste Stream Title
Geographic Distribution — Fraction
NE M? ENC WNC SA ESC WSC W M
Volume (lbs/yr )
• 007
• 125
.050
.033
.085
• 107
2879
2979
2879
Benzoic Herbicide Contaminated Containers
Calcium Arsenate Contaminated Containers
Carbamate Pesticide Contaminated Con—
--
.03
.0008
-—
.02
.016
.655
.08
.382
.154 .006
.07 .16
.070 .022
.017 -—
.16 .35
.108 .321
.160
.03
.060
.009
.09
.020
2X10
6X10 4
5 ) 10
User
SIC #B
G01,
2879
tainars
Chlorinated Aliphatic Pesticide Contazni—
.381
——
.076
.418 — —
.105 .010
.010
——
ixio
02,07
Fore8try
2879
2879
2879
2879
nated Containers
Dinitro Pesticide Contaminated Containers
Løad Arsenate Contaminated Containers
Mercury Fungicide Contaminated Containers
Miscellaneous Organic Pesticide Contami—
.496
.03
.02
.014
.168
.02
.03
.162
.023
.08
.04
.385
.017 .228
.07 .17
.03 .28
.068 .162
—- .003
.17 .35
.32 .05
.123 .041
.165
.08
.22
.034
.006
.03
.01
.014
2X10 4
1X10
5 Kb 4
1X10
-08
Trans.—40,
41,42,44,45
2879
nated Containers
Miscellaneous Organic Insecticide Contain—
.148
.084
.054
.039 .197
.143 .148
.170
.017
4Kb 4
2879
2879
2879
2879
2879
2879
mated Containers
Organic Arsenical contaminated Containers
Organic Fungicide Contaminated Containers
Orgar*ophosphoroue Contaminated Containers
Phanoxy Contaminated Containers
Ph.nyl—Urea Contaminated Containers
Polychlorinated Hydrocarbon Contaminated
--
.048
.043
.035
.106
.017
.764
.001
.192
.030
.424
.211
3
5x 10 4
8 K b 5
1Kb 5
2X10 3
9X10 5
2X10
2879
Containers
Triazine Contaminated Containers
.147
.121
.320
.372 .013
.003 .011
.011
.002
4
6X10
2879
Wastes from Pesticide—Herbicide Mama—
.005
.075
.145
.074 .299
.207 .090
.058
.046
factur. (Ars.nites)
2879
2879
Bensoic Herbicide Wastes (DOD,
Chlorinated Aliphatic Herbicide Wastes(DOD
.168
.196
.130
.062
.009
.027
- — .447
—— .649
-- ——
-- .010
.246
-—
——
.057
3X10
5X10 3
2879
Organic Arsenicals from Production of
--
.200
.800
-- --
-- --
--
-—
2879
2879
2879
Cacodylatee
Phenyl—Ursa Herbicide Wastes (DOD)
Phenoxy Herbicide WaStes (DOD)
Halogenated Aliphatic Hydrocarbon F sni-
.539
.0002
1.0
.059
.0001
-—
——
.0007
--
-- .343
—— .0008
-- —-
.059 --
.849 .149
-- --
.0004
--
.0002
—-
2X10
8X10 2
2X10
gant Wastes (DOD)
2879
Mercuric Fungicide Production Wastes
.005
.075
.145
.074 .299
.207 .090
.058
.046
2816
Chromate Wastes from Pigments and DyeS
.015
.170
.156
.047 .156
.111 .265
.060
.020
22
Chroinate Wastes from Textile Dying
.101
.178
.034
.005 .568
.034 .014
.060
.006
.047
.018
.196
.106
.019
.028
.125
.321
.033
.138
.011
.441
.139
.031
.106
.306
.218
036
.175
.067
.042
.133
.266
.208
.146
.095
.044
.007
.049
.141
.003
.024
7
2X10 r ixirnuin

-------
SIC I West. Stream Title
2865 Dye Manufacturing Wastes
283 Drug Manufacturing Wastes
2092 Nitrocellulose Propellant Contaminated
Wastes
2892 nigh Explosive Contaminated Wastes
2092 Waste Incindjarjeg
2092 Incindiary Contaminated Wastes
2892 Wastes from Production of Nitrocellulose
Propellants and Smokeless Powder
2092 Production of Nitroglycerin
2892 Solid Waste from Old Primers and
Detonators
2892 Contaminates and Waste from Primary
Explosives Production
2879 Miscellaneous Organic Herbicide Pro-
duction Wastes
2879 Phenoxy Herbicide Production Wastes
2092 Waste High Explosives
2892 Waste Nitrocelluloge and Smokeless
Powder
2892 Waste Nitroglycerin
2892 Contaminated and Wait. Industrial Pro-
pellants and Explosives
Contaminated Orchard Soil
Wastes from Seed Industry
Eighly Contaminated Soil (Stored)
Organic Pesticide Production Wastes
Organic Fungicide Production Wastes
.005 .094 .394 .397 .027
—— .014 .002 .002 —— ——
—— .060 .046 87 .477 ::
—— —— —— —— .42
—— .005 .430 .454 .001
—— .096 .001 .898 —— .001 —— .001 .003
.076 .135 .124 .080 .156 .062 .1 8 .200 .059
.135 .124 .080 .156
.006 .346 .174 .218
.594 .406
—— .01 —— .50 .22 —— .266 .004
—— —— —— .655 .344
.05 —— .15 —— .33
.017 .088 .371 .213 .053 .060 .081 .094 .023
—— —— -— 1.0
.057 .093 .183 .054
.062 .107 .202 .058
(Rocky Mountain
Ar sena 1)
Geographic Distribution — Fraction
NE MA ENC WNC SA ESC WSC W M
.015 .170 .156 .047 .156 .111 .265 .060 .020
.056 .348 .183
-— .041. ——
.089 .100
.457 .492
Vo1 m e (lbslvr)
.033 .060 .115 .011
—— — —— .009
.004
.718
106
5x10 ,
lXl O 7
9X10 5
6X10
6x lo
.012 .023
.255 .009
—— .025
.19 —— .39 —— 7X10 5
.006 —— .014 .084 3X10 5
.076
.002
0175
011.
072
9711
2879
2879
.062
.104
.108 .200 .059
.127 .001 .010
4x10 6
4x10 8
4x10 7
1X1O
2X10
5X10 5
3X 10
.115 .148 .136
.076 .135 .124
-- .35 .09 .03 Unknown
.073 .141
.086 .156
3X10 9
3x10 8
2x10 8

-------
SIC •
Waits Stream Title
Geographic Distribution — Fraction
NE MA ENC WNC SA ESC WSC N N
Volume (ibs/yr )
Solid Military Ars.nioal Wastes
Contaminated or Outdated Tsar Gal
Military Ordnance (MurLitioms & Explosives) --
Military Catuium Plating Wastes (US A !) —-
Spent Filter Media from Military Opera-
tioni
9711 Of f Spec “Agent Orange” Defoliant
9711 Paint Stripping Wastes, Vance Air Force -—
Base OX
Stored Military Mercury Compounds
Chrome Tanning Liquor
Nitrobensene from Rubber Industry
Wastes
Rubber Manufacturing Wastes
Synthetic Fiber Production Wastes
Acetaldehyde Via Ethylene Oxidation
Cellulose Ester Production Wastes
Wastes from Production of Chloropicrin
Nonutility PCB Wastes
2818 O Synthesis Methanol Production Wastes
2611. Dimethy]. Sulfate Production Wastes
2818 Formaldehyde Production Wastes
2818 N-Butane D.hydrogenation Butadiene
Production Wastes
2821 Wastes from Polycarbonate Polymer
Production
2821 Residue from Manufacture of Ethylene
Dichlorida/Viny ]. Chloride
2821 Urethane Manufacturing Wastes
- - —— - - - - -- 1.0 - - -- (Vance Air Force
Base, OX)
.47 —— — — .51 — — —— — — .02 —— 215
.22 .29 .29 .03 .086 .05 .004 .03 —— 2X10 9
— — .07 .14 -— .11 .11 .50 .07 —— 5XlO (probably too
dilute to be of con-
cern) 6
—— .07 .14 —— .11 .11 .50 .07 —— 1X1 O
.046 .12]. .101 .018 .404 .182 .101 .027 —— 7
.015 .170 .156 .047 .156 .111 .265 .060 .020 BX1O
.10 .21 .21 .16 .14 .07 .10 .02 ——
- - x -- -- —— —- x xx -- t4eg . 6
.037 .221 .372 .153 .040 .041 .057 .072 .009 8X10
—— .05 —— .05 —— .90 —— 1X10 5
—— —- —- — — 2X15
—— — .02 —— .05 —— .93 —— —— SX1O
— — —— .03 — — — — —— .92 .05 —— 3X 10
.046 .121 .101 .018 .404 .182 .101 .027
— — .021 .015 —— .163 .171 .533 .117 ——
9711
9711
9221
9711
9711
9711
9711
31
2822
—— .002 .001 —— .015 .031 .001 .926 .024
.138 .189 —— .022 .044 .252 .209 .144
3X10 6
3X 10
2X 10 6
2822
2824
281
28211
9711
2899
Sludge
Still Bottoms
Sludge
Sludge
2X10 7
.046 .121 .101 .018 .404
.182 .101 .027 ——

-------
Wood Preservative Wast•a
Spent Wood Preserving Liquors
Agricultural Ch ical Manufacturing
Wastes
2819 Arsenic Wastes from Purification of
Phosphoric Acid
3339 Beryllium Salt Production Wastes
2813 Boran. Production Wastes
2812 Chlorine Production Brine Sludges
2869 Contaminated Antimony Pentafluoride
2869 Contaminated Antimony Trifluoride
2819 Contaminated Fluorine
2813 Nickel Carbonyl Production Wastes
2819 Cyanide Production Wastes
2869 Nydrazine Production Wastes
287 Intermediate Agricultural Product Wastes
- Nitric Acid
2819 Potassiim Chromate Production Wastes
2873 Production Wastes for Arnmonium Sulfate
3339 Selenium Production Wastes
2819 Sodium Dichroinate Production Wastes
2869 Tetrauthyl and Tetralnethyl Lead Produc-
tion Waste.
2873 Urea Production Wastes
2813 Waste Bromine Pentafluoride
2813 Waste Chlorine Pentafluorjde
2813 Waste Chlorine Trifluoride
2819 Waste from Production of Barium Salts
2879 Organo—Phosphate Pesticide Production
Wastes
2879 Chioriftated Hydrocarbon Pesticide Pro-
duction Wastes
NE
MA
ENC
WNC SA
ESC
WSC
W
M
.007
.029
.117
.060 .267
.141
.174
.162
.042
4x10 2
.007
.029
.117
.060 .267
.005
.075
.145
.074 .299
.207
.174
.090
.162
.058
.042
.046
.015
.170
.156
.047 .156
.111
.265
.060
.020
Nag.
.02
--
.10
-- --
- - - -
—— .19
--
Meg.
Meg.
-—
-- - -
Meg.
.007
.166
-- -—
Meg.
.147
Meg.
.007
.166
.075 .147
Meg.
x
—-
--
.005
.145
x
.074 .299
.19
.06
.015
.005 .60
——
——
.04
— — — —
——
.75
——
— — ——
—— .05 .09 .18 .09 .15 .29 .14 —— 2X10 5
-- — — - - -- —- -- 1.0 - - - - Meg.
- — - - X - - -- -- x - - -- Meg.
—- —— X —- -- - - x —- —- Nag.
.007 .101 .166 .075 .147 .207 .147 .096 .054 Meg.
.115 .148 .136 .073 .141 .057 .093 .183 .054 6X10 7
.054
.054
.046
.01 .01
—— .96
—— .25
2X lo
1.0
1.0
.11
x
x
.101
1.0
.101
x
.075
lxi
1X10 (dry basis chromate)
2X10 (particulates)
3X 10 8
3X10
SIC I Waste Stream Title
2491
2865
2491
287
(A)
Volume (ibs/yr )
.12
.096
.096
.058
.22
.207
.207
.207
.10
.24
x
x
.147
.147
x
.090
.01
.170
.63
.37
(dry basis)
.115 .148 .136 .073 .141
.057 .093 .183 .054 2x10 8

-------
8xc I
Waste stream Title
NE MA
Geographic Distribution - Fraction
ENC WNC SA ESC WSC W M
Volume (ibs/yr )
10
TOTAL approximately 2 x 10 lbs/yr.
9.
or 9 X 10 kilograms/yr.
(10 million T/yr or approx. 9 million
.115
.131
.115
.115
.115
.115
• 115
.115
.115
.244
.03
.179
.285
.179
.179
.179
.179
.179
.179
.179
.198
.34
.379
321
379
.379
.379
• 379
.379
.379
.379
.149
.43
.046
.045
.046
.046
.046
.046
• 046
.046
.046
.095
.01
.050
.049
.050
.050
050
050
.050
.050
.050
• 081
.07
2819
Waits from Manufeotur. of Mercuric
-
1.0
--
--
--
--
--
--
—-
Meg.
3339
2813
Cyanide
Th.13 .ii Production Waites
Arsin. Production Wait.s
—-
x
——
x
--
x
--
--
--
--
——
x
1.0
x
——
x
—-
——
N .g. 4 (small amount in
1X1O Colorado)
Metal Finishing Wast.u
A1 aninum Anodizing Bath with Drag
.115
.115
.179
.2.79
.379
.379
.346
.046
.050
.050
.015
.015
.036
.036
.169
.169
.011
.011
4X1Q Cyanide Solution
BX1O Metal Sludges
Out
Brass Plating Wastes
Ca uium Plating Wastes
Chrome Plating Wastes
Cyanide Copper Plating Wastes
Finishing Effluents
Metal Cleaning Wastes
Plating Preparation Wastes
Silver Plating Wastes
Zinc Plating Wastes
33
Metal Finishing Chronic Acid
33].
Cold Finishing Wastes
9711
Waste Chemical, from Military
Etiological Material, from Commercial
Production
Cooling Tower Slowdown
.005
.150
.170
.060
--
.58
——
——
.035
2x10 7 (as Chromate)
2816
22
283
283
285
285
28
9711
Cadmium-Selenium Pigment Wastes
Mercury Bearing Textile Cleaning WaStes
Pharmaceutical Ar•enic Wastes
Pharmaceutical Mercurial Wastes
Water—Based Paint sludge
Solvent—Based Paint Sludge
Waste or Contaminated Perchloric Acid
Military Sodium Chromate (Stored)
.101
.056
.056
.044
.044
——
.178
.348
.348
.243
.243
——
.034
.183
.183
.269
.269
—-
.005
.089
.089
.072
.072
-—
.568
.100
.100
.103
.103
--
.034
.033
.033
.041
.041
——
.014
.060
.060
.069
.069
——
.060
.115
.115
.147
.147
——
.006
.011
.011
.012
.012
——
Meg.
Meg. 7
3X10 7
4X10
Meg.
2,765 (Okinawa)
.015
.023
.015
.015
.015
.015
.015
.015
.015
.032
.02
.036
.036
.036
.036
.036
.036
.036
.036
.036
.031
.05
.169
.103
.169
.169
.169
.169
.169
.169
.169
.031
.01
.011
.007 1X10 6
.011
.011
011
.011
.011
.011
.011
.041
04
5xl0
3X1 0
3X1 0
metric tons).

-------
Table B—2
States within Bureau of Census Regions
New England Mid Atlantic East North Central West North Central South Atlantic
Maine New York Wisconsin North Dakota West Virginia
Vermont Peansylvania Michigan South Dakota Delaware
New Hampshire New Jersey Illinois Minnesota Maryland
Massachusetts Indiana Nebraska Virginia
Rhode Island Ohio Iowa North Carolina
Connecticut Kansas South Carolina
Missouri Georgia
Florida
District of Columbia
East South Central West South Central Mountain Pacific Iest )
Kentucky Oklahoma Montana Washington
Tennessee Arkansas Idaho Oregon
Mississippi Texas Wyoming California
Alabama Louisiana Arizona Hawaii
New Mexico Alaska
Utah
Nevada
Colorado

-------
Table B-3
MISCELLANEOUS INORGANICS
A Sanqle List of Nonradioactive Hazardous Compounds
Aninonium Chremate
Minonium Dichromate
Antimony Pentafi uoride
Antimony Tn fluoride
Arsenic Trichioride
Arsenic Trioxide
Cadmium (Alloys)
Cadmium Chloride
Cadmium Cyanide
Cadmium Nitrate
Cadmium Oxide
Cadmium Phosphate
Cadmium Potassium Cyanide
Cadmium (Powdered)
Cadmium Sulfate
Calcium Arsenate
Calcium Arsenite
Calcium Cyanides
Chromic Acid
Copper Arsenate
Copper Cyanides
Cyanide (Ion)
Decaborane
Diborane
Hexa borane
Hydra zine
Hydrazine Azide
Lead Arsenate
Lead Arsenite
Lead Azide
Lead Cyanide
Magnesium Arseni te
Manganese Arsenate
Mercuric Chloride
Mercuric Cyanide
Mercuric Dianinonlum
Chloride
Mercuric Nitrate
Mercuric Sulfate
Mercury
Nickel Carbonyl
Nickel Cyanide
Pentaborane -9
Pentaborane -11
Perchioric Acid (to 72%)
Phosgene (Carbonyl Chloride)
Potassium Arsenite
Potassium Chromate
Potassium Cyanide
Potassium Dichromate
Selenium
Silver Azide
Silver Cyanide
Sodium Arsenate
Sodium Arsenite
Sodium Bichromate
Sodium Chromate
Sodium Cyanide
Sodium Monofluoroacetate
Tetra borane
Thallium Compounds
Zinc Arsenate
Zinc Arsenite
Zinc Cyanide
HALOGENS & IPITERHALOGENS
Bromine Pentafluoride
Chlorine
Chlorine Pentafluoride
Chlorine Trifluoride
Fluorine
Perchi oryl Fl uori de
MISCELLANEOUS ORGANI S
Ac role in
Alkyl Leads
Carcinogens (In General)
Chloropicrin
Copper Acetylide
Copper Chiorotetrazole
Cyanuric Triazide
Diazodinitrophenol (DDNP)
Dimethyl Sulfate
Di ni trobenzene
Dinitro Cresols
Di ni trophenol
Di ni trotol uene
Dipentaerythritol Hexanitrate
(DPEHN)
GB (Propoxy(2)-methylphosphoryl
fluoride)
Gelatinized Nitrocellulose
(PNC)
Glycol Dinitrate
Gold Fulminate
86
Lead 2,4-Dinitroresorcinate
(LDNR)
Lead Styphnate
Lewisite (2-Chioroethenyl
Dichloroarsine)
Mannitol Hexanitrate
Nitroanil me
Nitrocellulose
Nitrogen Mustards (2,2’,2’
Tn chl orotri ethyl amine)
Nitroglycerin
Organic Mercury Compounds
Pentachi oro phenol
Picric Acid
Potassium Dinitrobenzfuro—
xan (KDNBF)
Silver Acetylide
Silver Tetrazene
Tear Gas (CN) (Chioroaceto-
phenone)
Tear Gas (CS) (2-Chioroben-
zylidene Malononitrile)
Tetrazene
VX (Ethoxy-rnethyl phos-
phoryl N,N dlpropoxy-(2-
2), thiocholine)
ORGANIC HALOGEN COMPOUNDS
Aidrin
Chlorinated Aromatics
Chlordane
Copper Acetoarseni te
2,4-D (2,4-Dichiorophenoxy-
acetic Acid)
DDD
DDT
Deme ton
Dieldrin
Endrin
Ethylene Bromide
Fluorides (Organic)
Guthi on
Heptachi or
Li ndane
Methyl Bromide
Methyl Chloride
Methyl Parathion
Parathion
Po ori nated BIphenyl s

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Table 8—4
Potentially Hazardous Radionuclides*
Nuclide Half—Life, Years Sourcet Nuclide Half-Life, Years Sourcet
1—3 12.33 1,2,3 Sm-151 93. 1
Be-lO 1,600,000. 2 Eu-152 13. 1
C-14 5730. 2 Eu-154 8.6 1
Na-22 2.601 2 Eu-l S S 4.8 1
Ci -36 301,000. 2 Gd-153 0.662
Ar—39 269. 2 Ho-l6f 1200. 1
Ca -41 130,000. 2 Tm-l70 0.353 3
Ca-45 0.447 2 Ta-182 0.315 3
V-49 0.907 2 I1-181 0.333 2
Mfl 5 4 0.856 2 Ir-192m 241. 3
Fe-55 2.7 2 Pb_210** 22.3 1,2
Co-60 5.27 2,3 Bi-210 3,500,000. 1
Ni-59 80,000. 2 Po-210 0.379 2,3
Ni-63 100. 2 Ra_226** 1,600. 1,2
Se-79 65,000. 1 Ra_228** 5•75 1
Kr-85 10.73 1 Ac_227** 2L77 1
Sr_90** 29. 1,3 Th_228** 1.913 1
Zr_93 * 950,000. 1 Th_229** 7,340. 1
Nb—93n 12. 1,2 Th_230** 77,000. 1,2
Nb-94 20,000. 2 Pa_231** 32,500. 1
Mo-93 3,000. 2 IJ_232** 72. 1
Tc-99 213,000. 1 lJ_233** 158,000. 1
Ru_106** 1.011 1,3 U_234** 244,000. 1
Rh-lOan 0.567 1 tJ-236 23,420,000. 1
Pd-107 6,500,000. 1 Np-237 2,140,000. 1
Ag-1l0n 0.690 1 Pu_236** 2.85 1
Cd- 109 1.241 1 Pu_238** 87.8 1,3,2
Cd-113m 14.6 1 Pu-239 24,390. 1,2
Sn-12 1m 50. 1 Pu_240** 6,540. 1,2
Sn-123 0.353 1 Pu_241** 15. 1,2
Sn- 126 100,000. 1 Pu_242** 387,000. 1
Sb-125 2.73 1,2 Am_241** 433. 1,3
Te—127m 0.299 1 Am-242m 152. 1
1-129 15,900,000. 1 Am_243** 7,370. 1
Cs-134 2.06 1 Cm_242** 0.446 1,3
Cs—135 2,300,000. Cm_243** 28. 1
Cs_137** 30.1 1,3 Cm_244** 17.9 1,3
Ce 144** 0.779 1,3 Cm_24 5 ** 8,500. 1
Pm-146 5.53 1 Cnl_246** 4,760, 1
Pm— 147 2.5334 1,3 Cm 247* 15,400,000. 1
* Criteria for inclusion of nuclides are:
(a) That they have half-lives greater than 100 days. Nuclides with half-lives less than
100 days are assumed to decay to insignificance before disposal or are included in their
long half-life parents. Note that this excludes nuclides such as 1-131 with an 8.065-day
half-life.
(b) That they shall not be naturally occurring because of their own long half-lives. This
table excludes such nuclides as K-40, Rb-87, Th-232, U-235, and U-238 with half-lives greater
than 108 years. There are also 75 potentially hazardous radionuclides that occur in research
quantities that have not been included in this table.
t Source tern :
(1) Found in high-level radioactive wastes from fuel reprocessing plants, both government
and industry.
(2) Found in other nuclear power wastes such as spent fuel cladding wastes, reactor emissions
and mine and mill tailings.
(3) Found in wastes of nonnuclear power origin such as nuclear heat sources, irradiation
sources, and biomedical applications.
** Indicates hazardous daughter radionuclides are present with the parent.
87

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Appendix C
DECISION MODEL FOR SCREENING,SELECTING, AND RANKING HAZARDOUS WASTES
This preliminary decision model was developed for interim use* in
order to screen and select hazardous compounds and rank hazardous wastes.
This appendix provides an explanation of the terminology and definitions
utilized, and the exact mechanism for screening, selecting, and ranking.
It is essential to make a clear distinction between development and
application of criteria for purposes of designating hazardous wastes
and development and application of a priority ranking system for hazardous
wastes despite the fact that similar or related data must be manipulated.
The distinction is that the hazardous waste criteria relate solely to
the intrinsic hazard of the waste on uncontrolled release to the environ-
ment regardless of quantity, pathways to man or other critical organisms.
Therefore criteria such as toxicity, phytotoxicity, genetic activity,
and bloconcentration were utilized.
In contrast, in the development of a priority ranking system, it is
obvious that the threat to public health and environment from a given
hazardous waste is strongly dependent upon the quantity of the waste
involved, the extent to which present treatment technology and regulatory
activities mitigate against the threat, and the pathways to man or other
critical organisms.
Criteria for Screening and Selection
The screening criteria are based purely on the inherent or intrinsic
characteristics of the waste as derived from its constituent hazardous
compounds. The problem in seeking a set of criteria becomes one of
establishing for public health and the environment some acceptable level
of tolerance. Wastes displaying characteristics outside of these pre-
determined tolerance levels are designated as hazardous. This approach
requires that defensible thresholds be selected for each tolerance level.
For example, if the toxicity threshold is defined as an LD5O of 5,000
mg/Kg of body weight or less, all wastes dieplaying equal or lower mean lethal
dose levels would be designated hazardous. Similar nLtneric threshold values
were developed for other basic physical, chemical or biological criteria
utilized In the screening phase of the decision model. Ideally then,
the decision criteria for designating hazardous wastes could be based
upon numeric evaluations of intrinsic toxicological, physical, and
chemical data.
* The decision model used for purposes of this study is not nearly
as sophisticated as that required for standard setting purposes.
88

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In addition, a criteria system for screening hazardous wastes must
retain a degree of flexibility. This is self—evident because all poten-
tial wastes cannot now be identified, let alone their composition. Con.-
sequently, it appears that a technically sound and administratively work-
able criteria system must have levels of tolerance against whiôh any waste
stream can be compared.
As a result a preliminary screening model was developed as illustrated
in Figure C-l. Each stage of the screening mechanism compares the charac-
teristics of a waste stream to some preset standard. Qualification due
to any one or more screens automatically designates a waste as hazardous.
Explanations of those terms that have been utilized in the screerning model
in Figure C-l are enclosed at the end of this appendix.
Priority Rankin2 of Wastes
There is little doubt that, on the basis of intrinsic properties
alone, many wastes will qualify as hazardous wastes. Therefore it was
necessary to rank these wastes in priority fashion so that those pre-
senting the most iminent threats to public health and the environment
receive the greatest attention.
To assess the magnitude of the threat posed by hazardous wastes is
difficult. Such a determination requires input concerning the inherent
hazards of the wastes, the quantities of waste produced, and the ease with
which those hazards can be eliminated or circumvented. These considerations
were incorporated into numerical factors, which in turn were used to
determine the priority-of-concern of a particular waste. The final numeri-
cal factor is designed to represent the volume of the environment poten-
tially polluted to a critical level by a given waste. The assumption is
made that all sectors of the environment are equally valuable so that a
unit volume of soil is as important as a unit volume of water or air.
This simplification does not reflect the fact that atmospheric and aquatic
contaminants are more mobile than terrestrial ones, but does recognize
the problem of environmental transfer from one phase to another.
The numerical factor is derived by dividing the volume of a waste
by Its lowest critical product. This may be expressed mathematically as
R=
where R = ranting factor
Q = annual production quantity for the waste being ranked
CP = critical product for the waste being ranked
A critical product is the lowest concentration at which any of the
hazards of concern become manifest in a given environment multiplied by
89

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Figure C-i
Graphic Representation of the Hazardous Waste Screening Model*
WASTE STREAMS
DOES WASTE CONTAIN YES
RADIOACTIVE CONSTITUTES
> MPC LEVELS?
_________ NO
E } YES
ISWAST [ FLAMMABILIr( YES
IN NFPA CATAGORY 4?
NO
IS WASTE REACTIVITY YES
INNFPA CATAGORY4?
NO
DOES WASTEHAVEANORALED YES
5OMGIKG?
NO
IS WASTE INHALATION TOXICITY YE
2OOppm GASORMIST? —
LC%<2 MG1I AS DUST?
NO
IS WASTE DERMAL PENETRATION
lOX IC liv 200 MG/KG?
JNO
IS WASTE DERMAL IRRITATION YES
REACTION <
_________ NO
DOES WASTEHAV QUAT IC1 YES
96 HR TLM ____________
_____ NO
IS WASTE PHYTOTOXICITYf ________________________
I L ’ 1D0O MG/i? J
NO
DOES WASTE CAUSE GENETIC __________________________
- CHANCES?
L THEI WASTES AZARDOUS WASTE J
* fjfljtjoflS of terms are given on p. 91
90

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an index representative of the waste’s mobility into that environment.
Hence, for a waste which will be discharged to water or to a landfill
where leaching will occur, the product might be the 96 hour Tim to fish
for that waste (e.g. 1 mg/i) multiplied by its solubflity index. The
solubility index is defined as a dimensionless number between 1 and
infinity obtained by dividing i 6 mg/i by the solubility of the waste in
mg/l. A waste soluble in water to 500,000 mg/i has a solubility index
of:
SI = i0 6 / 5x10 5 = 2
This presumes that all wastes miscible in water or soluble to more than
1,000,000 mg/i will have simflar mobility patterns and thus should receive
a maximum index of 1. The critical product for the example waste would
then be:
CP = 96 hr TLm X SI
C I ’ = 1 mg/i X 2 2 mg/i
Similarly, for atmospheric pollutants the critical product might
be the IC 50 multiplied by the volatility index. This index would be
derived by dividing atmospheric pressure under ambient conditions by
the vapor pressure of the waste. Potential for suspension of dusts in
air would be given a mobility index of 1.
The aqueous and atmospheric environments are of greatest concern
since discharge to the land represents major hazards in the form of
volatilization of wastes or leaching. Where data are available on
phytotoxicity or other hazards related to direct contact with wastes In
soil, the critical product for ranking would be derived from use of the
critical concentration at which the hazard becomes apparent, and a
mobility index of 1.
Actual waste stream data is most desirable for use in the priority
ranking formulation. However, since such data are generally lacking,
the additive estimations recomended for interim use can be employed
for priority ranking until waste stream data beeoe available.
Definitions of Abbreviations Used in the Screening Model in Table C-i
Maximum Permissible Concentration (MPC) Levels . These are levels of
radiolsotopes in waste streams wMch if continuously maintained, would
result in maximum permissible doses to occupationally-exposed workers,
and may be regarded as Indices of the racliotoxicity of the different
radionuci ides.
Bioconcentration ( bioaccumu1ation, biomag ification) . The process by
which llvfng organisms concentrate an element or compound to levels in
excess of those in the surrounding environment.
91

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National Fire Protection Association (NFPA).
Category 4 Flamable Materials . These materials include very flamable
gases, very volatile flaniriable liquids, and materials that in the form
of dusts or mists readily form explosive mixtures when dispersed in air.
NFPA Category 4 Reactive Materials . These are materials which in
themselves are readily capable of detonation or of explosive decompo-
sition or reaction at normal temperatures and pressures.
Lethal Dose Fifty A calculated dose of a chemical substance
which Is expected to viii 50 percent of a population of experimental
animals exposed through a route other than respiration. Dose con-
centration is expressed in milligrams per kilogram of body weight.
Lethal Concentration Fifty (LC oj . A calculated concentration which
when administered by the respiratory route would be expected to kill
50 percent of a population of experimental animals during an exposure
of 4 hours. Ambient concentration is expressed in milligrams per liter.
Grade 8 Dermal Irritation . An Indication of necrosis resulting from
skin Irritation cause fby application of a 1 percent chemical solution.
96 Hour Thm çmedian threshold limit) . That concentration of a material
at hich it is lethal to 50 percent of the test population over a 96
hour exposure period. Ambient concentration is expressed in milligrams
per liter.
Phytotoxicity . Ability to cause poisonous or toxic reactions in plants.
Median Inhibitory Limit (ILm) . That concentration at which a 50 percent
reduction In the blomass, céTi count, or photosynthetic activity of the
test culture occurs when compared to a control culture over a 14 day
period. Ambient concentration is expressed in milligram per liter.
Genetic Changes . Molecular alterations of the deoxyribonucleic or ribo-
nucleic acids of mitotic or melotic cells occurring from chemicals or
electromagnetic or particulate rdfation.
92

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Appendix D
SUMMARY OF HAZARDOUS WASTE TREATMENT
AND DISPOSAL PROCESSES
The objectives of hazardous waste treatment are the destruction
or recovery for reuse of hazardous substances and/or conversion of these
substances to innocuous forms which are acceptable for uncontrolled
disposal. Several unit processes are usually required for complete
treatment of a given waste stream. In some cases, hazardous residues
result from treatment which cannot be destroyed, reused or converted to
Innocuous forms. These residues, therefore, require controlled storage
or disposal.
This appendix presents a description of each of the treatment and
disposal processes examined during this study. No claim is made that
these hazardous waste treatment processes or combinations of processes
and storage or disposal methods are environmentally acceptable. Treat-
ment technology can be grouped into the following categories: physical,
chemical, thermal, and biological. These processes are all utilized to
some extent by both the public and private sectors. However, treatment
processes have had only limited application in hazardous waste manage-
ment because of economic constraints, and, in some cases, because of
technologi cal constraints.
The physical treatment processes are utilized to concentrate waste
brines and remove soluble organics and amonia from aqueous wastes.
Processes such as flocculation, sedimentation, and filtration are widely
used throughout industry, and their primary function is the separation
of precipitated solids from the liquid phase. Anmonia stripping is
utilized for removing amonla from certain hazardous waste streams.
Carbon sorption will remove many soluble organics from aqueous waste
streams. Evaporation is utilized to concentrate brine wastes in order
to minimize the cost of ultimate disposal.
The chemical treatment processes are also a vital part of proper
hazardous waste management. Neutralization is carried out in part by
reacting acid wastes with basic wastes. Sulfide precipitation Is
required in order to remove toxic metals like arsenic, cadmium, mercury,
and antimony. Oxidation-reduction processes are utilized in treating
cyanide and chromium-6 bearing wastes.
Thermal treatment methods are used for destroying or converting
solid or liquid combustible hazardous wastes. Incineration is the
standard process used throughout industry for destroying liquid and
solid wastes. Pyrolysis is a relatively new thermal process that is
used to convert hazardous wastes into more useful products, such as fuel
gases and coke.
93

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Biological treatment processes can also be used for biodegrading
organic wastes; however, careful consideration needs to be given to the
limitations of these processes. These systems can operate effectively
only within narrow ranges of flow, composition, and concentration varia-
tions. Biological systems generally do not work on solutions containing
more than 1-5 percent salts. Systems which provide the full range of
biodegradation facilities usually require large land areas. Toxic
substances present a constant threat to biological cultures. In summary
biological treatment processes should be used only when the organic
waste stream is diluted and fairly constant in Its composition.
Disposal methods currently used vary depending upon the form of
the waste stream (solid or liquid), transportation costs, local
ordinances, etc. Dumps and landfills are utilized for all types of
hazardous wastes; ocean disposal and deep well Injection are used
primarily for liquid hazardous wastes. Engineered storage or a secure
landfill should be utilized for those hazardous wastes for which no
adequate treatment processes exist.
In Table D-1,each of the processes evaluated by EPA is described in
more detail. Also provided is an assessment of each process’s waste
handling capabilities. The most widely applicable processes are
Incineration, neutralization, and reduction.
94

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Table D-l
Summary of Hazardous Waste
Treatment arid Disposal Processes
Physical Treatment
Processes
Description
Waste Handling Capability
C ,’
1. Reverse Osmosis
2. DialysIs
1. The physical transport of a solvent
across a membrane boundary, where external
pressure is applied to the side of less
solvent concentration so that the solvent
will flow in the opposite direction. This
allows solvent to be extracted from a
solution, so that the solution is
concentrated and the extracted solvent Is
relatively pure.
2. A process by which various substances
in solution having widely different
molecular weights may be separated by
solute diffusion through semi-permeable
membranes. The driving force is the
difference in chemical activity of the
transferred species on the two sides of
the membrane.
I. Almost any dissolved solid can
be treated by reverse osmosis,
provided the concentrations a e
not too high and it Is practical
to adjust the pH to range 3—8.
2. The oldest continuing commercial
use of dialysis is in the textile
industry. Dialysis is particularly
applicable when concentrations are
high and dialysis coefficients are
disparate. It is a suitable means
of separation for any materials on
the hazardous materials list which
form aqueous solutions.
3. Electrodlalysis
3. SImilar to dialysis in that dissolved
solids are separated from their solvent by
passage through a semi-permeable membrane.
It differs from dialysis in Its dependence
on an electric field as the driving force
for the separation.
3. Electrodialysis is applicable
when It Is desired to separate
out a variety of ionized species
from an unionized solvent such as.
water. Ionizable nitrates and
phosphates (e.g. Pb(NO ) 2 , Na 3
P0 4 ) are removed with varying
degrees of efficiency. With
regard to NDS, electrodialysis is

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Physical Treatment
Processes
Description
Waste Handling Capablflty
applicable for the treatment of
waste streams where it is desirable
to reduce the concentrations of
Ionizable species in the inteniied—
late range (10,000 ppm to 500 ppm)
over a broad range of pH (e.g.,
pH 1 to 14). If an effluent of
concentration lower than 500 ppm
is desired, the electrodlalysis
effluent could be fed into another
treatment process.
4. EvaporatIon
4. The removal of solvent as vapor from a
solution or slurry. This Is normally
accomplished by bringing the solvent to its
boiling point to effect rapid vaporization
Heat energy Is supplied to the solvent and
the vapor evolved must be continuously
removed from above the liquid phase to
prevent Its accumulation. The vapor
may or may not be recovered depending on
its value. Thus, the principal function
of evaporation is the transfer of heat
to the liquid to be evaporated.
4. Evaporation processes are
widely used throughout Industry
for the concentration of solutions
and for the production of pure
solvents. Evaporation represents
the most versatile wastewater
processing method available that
is capable of producing a high
quality effluent. It is, however,
one of the most costly processes
and is therefore generally limited
to the treatment of wastewaters
with high solids concentrations
or to wastewater where very high
decontamination is required (e.g.,
radioactive wastes).

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Physical Treatment
Processes
Description
Waste Handling Capabilit
5. Carbon Sorption
6. AmmonIa Stripping
5. Sorption is said to occur when a
substance is brought into contact with a
solid and is held at the surface or inter-
nally by physical and/or chemical forces.
The solid is called the sorbent and the
sorbed substance is called the sorbate.
The amount of sorbate held by a given
quantity of sorbent depends upon several
factors including the surface area per unit
volume or weight) of the sorbent
and the intensity of the attractive forces.
Activated carbon has been historically
used to remove organic and other
contaminants from water.
6. Ammonia can be readily removed from
alkaline aqueous wastes by stripping with
steam at atmospheric pressure, The waste
stream, at or near its boiling point, is
introduced at the top of a packed or
bubble cap tray type column and contacted
concurrently with steam. Due to Its high
partial pressure over alkaline solutions,
aimionia is condensed and reclaimed for
sale, and liquid effluents from a properly
designed steam stripping column will be
essentially ammonia free.
5. Activated carbon •sorption
has been used to remove dissolyed
refractory organics from municipal
waste streams and to clean up
Industrial waste streams. It has
been used to remove some heavy
metals and other inorganics from
water. Carbon sorption can
remove most types of organic wastes
from water. Those which have low
removal by carbon include short
carbon chain polar substances such
as methanol, formic acid, and perhaps
acetone. This process is being
utilized to treat herbicide plant
wastes. Also, full scale carbon
sorption units have been success-
fully used for petroleum and
petrochemical wastes.
6. This process is quite useful
in the treatment of amonia
bearing wastes. However, It can
also be used to remove various
volatile and organic contaminants
from waste streams.

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Physical Treatment
Processes
7. FiltratIon
8. SedImentation
(settling)
7. ThIs process Involves the physical removal
of the solid constitutes from the aqueous waste
stream. A slurry is forced against a filter
medium. The pores of the medium are small
enough to prevent the passage of some of the
solid particles; others Impinge on the fiber
of the medium. Consequently, a cake builds
up on the filter and after the initial
deposition, the cake Itself serves as the
barrier. The capacity of this process is
governed by the rate of the fluid filtrate
through the bed formed by the solid particles.
8. This process is used to separate aqueous
waste streams from the particles suspended in
is placed In a tank,
allowed to settle out;
removed from above the
state is that of a
a filter cake If the
continue long enough.
9. This process Is used when fine particLes
in a waste stream are d ff1cult to separate
from the medium in which they are suspended.
These waste constituents are in the low and
fractional micron-range of sizes, they settle
too slowly for economic sedimentation and
they are often difficult to filter. Thus,
this process Is applied to gather these
particles together as flocculates which
allows them to settle much faster and the
resulting sediment is less dense and is
often mobile. The particles also filter
more readily into a cake which Is permeable
and does not clog.
Waste Handling Capability
7. Most of the aqueous
hazardous waste streams which
contain solid cOnstituents
will be treated by this process.
8. SedImentation is widely
used throughout industry for
treatment of waste streams
for which there is a need for
separation of precipitated
solids from the liquid phase.
9. Flocculation Is also
widely used throughout In .-
dustry for treatment of waste
streams for which there is
a need for separation of
precipitated solids from the
liquid phase.
Description
them. The suspension
and the particles are
the fluid can then be
solid bed. The final
packed bed resembling
process Is allowed to
9. Flocculation

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Chemical Treatment
0
Processes
1. Ion Exchange
2. Neutralization
Description
1. The reversible interchange of ions
between a solid and a liquid phase In
which there is no permanent change in
the structure of the solid. It Is a
method of collecting and concentrating
undesirable materials from waste streams.
The mechanism of ion exchange is chemical,
utilizing resins that react with either
catlons or anions.
2. This method is utilized to prevent
excessively acid or alkaline wastes from
being discharged in plant effluents. Some
of the methods utilized to neutralize such
wastes ire: (a) mixing wastes such that
the net effect is a near-neutral pH; (b)
passing acid wastes through beds of limestone;
Cc) mixing acid with lime slurries; (d)
adding proper proportions of concentrated
solutions of caustic soda NaOH) or soda
ash to acid waste waters; e) blowing waste
boiler—flue gas through alkaline wastes,
(f) adding compreesed CO 2 to alkaline
waste; and (h) adding suTfuric acid to
alkaline wastes.
Waste Handflng Capability
1. Ion exchange technology has
been available and has been
employed for many years for
removing objectionable traces of
metals and even cyanides from
the various waste streams of the
metal process industries.
Objectionable levels of fluorides,
nitrates, and manganese have also
been removed from drinking water
sources by means of Ion exchange.
Technology has been developed to
the extent that the contaminants
that are removed can either be
recycled or readily transformed
into a harmless state or safely
disposed.
2. Neutralization is utilized in
the precipitation of heavy metal
hydroxides. or hydrous oxides and
calcium sulfate.

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Cheulcal Treatment
Processes Description Waste Handling Capability
3. OxIdation 3. This Is a process by which waste streams 3. ThIs process is used in the
containing reductants are converted to treating of cyanides and other
a less hazardous state. Oxidation may be reductants.
achieved with chlorine, hypochiorites,
ozone, peroxide, and other comon oxidizing
agents. The method most comonly applied on
a large scale Is oxidation by chlorine.
4. Reduction 4. ThIs is a process whereby streams 4. This process Is used to
containing oxidants are treated with treat chroinlum—6 and other
sulfur dioxide to reduce the oxidants to oxidants.
less noxious materials. Other reductants
which can be used are sulfite salts and
ferrous sulfate depending on the
availability end cost of these materials.
5. PrecipitatIon 5. The process of separating solid 5. This process Is applicable
constituents from an aqueous waste to the treatment of waste streams
stream by chemical changes. In this containing heavy metals.
process, the waste stream is converted
from one with soluble constituents to
one with Insoluble constituents.
6. Calclnation 6. The process of heating a waste 6. Calcination is conunonly applied
material to a high temperature but in the processing of high—level
without fusing In order to effect useful radioactive wastes.
changes, such as oxidation or pulverization.

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Thermal Treatment
Processes
1. Incineration
Description
1. A controlled process to convert a
waste to a less bulky, less toxic, or less
noxious material. Most Incineration
systems contain four basic components:
namely, a waste storage facility, a burner
and combustion chamber, an effluent
purification device when warranted, and
a vent or a stack. The (11) basIc types
of incineration untts are: open pit, open
burning, multiple hearth, rotary kiln,
fluidized bed, liquid combusters, catalytic
combustors, after burners, gas combustors,
and stack flares.
Waste Handling Capability
1. The type of waste for which
each of these Incineration units
is best suited is detailed
dlagrannatically In Figure D-1.
2. Pyrolysis
2. The thermal decomposition of a compound.
Wastes are subjected to temperatures of
about 1200°F, (648°C), plus or minus
300°F(148°C), depending upon the nature of
the wastes, in an essentially oxygen—free
atmosphere. Without oxygen, the wastes
cannot burn and are broken down (pyrolyzed)
into steam, carbon oxides, volatile vapors
and charcoal.
2. Most municipal and industrial
wastes which are basically organic
in nature can be converted to coke
or activated charcoal and gaseous
mixtures which may approach natural
gas in heating values through the
utilization of pyrolysis.

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Figure D-l
Types of Incinerators and Their Applications

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-l
o
(A)
Biological Treatment
Processes
1. Activated Sludge
Process
Description
‘I. The activated sludge process may
be defined as a system In which
biologically active growths are contin-
uously circulated and contacted with
organic waste In the presence of oxygen.
Normally, oxygen Is supplied to the
system in the form of fine air bubbles
under turbulent conditions. The activated
sludge Is composed of the biologically
active growths and contains microorganisms
which feed on the organic waste. Oxygen
Is required to sustain the growth Of the
microorganisms. In the conventional
activated sludge process incoming
waste water Is mixed with recycled
activated sludge and the mixture is
aerated for several hours In an
aeration tank. During this period,
adsorption, flocculation, and various
oxidation reactions take place which
are responsible for removing much of
the organic matter from the waste water.
The effluent from the aeration tank
Is passed to a sedimentation tank where
the flocculated microorganisms or
sludge settles out. A portion of this
sludge I s recycled as seed to the
Influent waste water.
Waste Handling Capability
1. The activated sludge process
has been applied very extensively
in the treatment of refinery,
petrochemical, and biodegradable
organic waste waters.
2. Aera$ed Lagoon
2. A basin of significant depth
(usually 6 to 17 feet or 1.83 to 5.19
meters), In which organic waste
stabilization is accomplished by a
dispersed biological growth system, and
where oxygenation Is provided by mechanical
or diffused aeration equipment.
2. Aerated Lagoons have been
used successfully as an economical
means to treat Industrial wastes
where high quality effluents are
not required.

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Biological Treatment Processes
Description
Waste Handling Capability
3. Trickling Filter
3. Trickling filters are artificial
beds of rocks or other porous me-
dia through which the liquid from
settled organic waste is percolated.
In the process the waste is brought
into contact with air and biological
growths. Settled liquid is applied
intermittently or continuously over
the top surface of the filter by
means of a djstributor. The fil-
tered liquid is collected and dis-
charged at the bottom. The primary
removal of organic material is not
accomplished through filtering or
straining action. Removal is the
result of an adsorption process
similar to activated sludge which
occurs at the surfaces of the bio-
logical growths or slimes covering
the filter media.
3. Trickling filters have been
used extensively in the treat-
ment of industrial wastes such
as: acetaldehyde, acetic acid,
acetone, acrolein, alcohols,
benzene, butadiene, chlorinated
hydrocarbons, cyanides, epichlo-
rohydrin, formaldehyde, formic
acid, ketones, monoethanolamines,
phenol ics, proplylenedichioride,
terpenes, ammonia, amrnonium
nitrate, nylon and nylon chemical
intermediates, resins, and
rocket fuels.
4. Waste Stabilization Ponds
4. Waste Stabilization Ponds are large
shallow basins (usually 2 to 4 feet
or 0.61 to 1.22 meters deep) used
for the purposes of purifying waste
water by storage under climatic
conditions that favor the growth of
algae. The conversion of organics
to inorganics or stabilization in
such ponds results from the com-
bined metabolic activity of bac-
teria by the algae and by surface
aeration. Wiste stabl1iz tion oonds
have been widely used where land is
plentiful and climatic conditions
are favorable.
4. They have been used extensively
in treating industrial wastewaters
when a high degree of purification
is not required. More recently,
stab11lz tion pønds have proven to
be successful in treating steel mill
wastes.

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Ultimate Disposal
Processes
Description
Waste Handling Capability
1. LandfIll Disposal
1. A well controlled and sanitary method of
disposal of wastes upon land. Comon land-
fill disposal methods are: (a) mixing with
soil, (b) shallow burial, and (c) combina-
tions of these.
1. The utilization of landfill
procedures for the disposal of
certain hazardous waste materials
at a NDS, in an industrial
environment, or In municipal
applications will undoubtedly be
required in the future.
( 7 1
2. Deep Well Disposal
2. A system of disposing of raw or treated,
filtered hazardous wastes y pumping the
waste into deep wells where they are
contained in the pores of the permeable sub-
surface rock, separated from other ground-
water supplies by Impermeable layers of rock
or clay.
2. Subsurface Injection has been
eztenslvely used in the disposal
of oil field brines (between
10,000 and 40 000 brine injection
wells in u.s.5. The number of
industrial waste injection wells
in the U.S. has increased to more
than 100. Injection wells can be
used by virtually any type of
industry which is located In the
proper geologic environment and
which has a waste product amenable
to this method. Industries
presently using this method are
chemical and pharmaceutical plants,
refineries, steel and metal
Industries, paper mills, coke plants,
etc.
3. Land Burial
Disposal
3. Adaptable to those hazardous materials
that require permanent disposal. Disposal
is accomplished by either near—surface or
deep burial. In near-surface burial, the
material is deposited either directly into
the ground or Is deposited in stainless
steel tanks or concrete lined pits beneath
3. At the present time, near—surface
burial of both radioactive and
chemical wastes are being conducted
at several AEC and comercially
operated burial sites. Pilot plant
studies have been conducted for deep
burial in salt formations and hard

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Ultimate Disposal
Processes
Descri t1on
the ground. In land burial the waste is
transported to the selected site, where
it is prepared for final burial.
Waste Handling Capability
bedrock. Land burial Is a possible
choice for the hazardous materials
that require complete containment
and permanent disposal. This includes
radioactive wastes as well as highly
toxic chemical wastes. At the
present time only near-surface burial
is used for the disposal of most
wastes.
4. Ocean Dumping
4. The process of utilizing the ocean as
the ultimate disposal sink for all types
of waste materials (Including hazardous
wastes). There are three basic techniques
for ocean disposal of hazardous wastes. One
technique Is bulk disposal for liquid or
slurry—type wastes. Another technique Is
stripping obsolete or surplus World War II
cargo ships, loading the ships with obsolete
munitions, towing them out to sea, and
scuttling them at s ue designated spot. The
third technique is the sinking at sea of
containerized hazardous toxic wastes.
4. The broad classes of hazardous
wastes dumped at sea have been
categorized as follows: Industrial
wastes; obsolete, surplus, and
nonserviceable convention explosive
ordinance and chemical warfare
and miscellaneous hazardous wastes.
5. EngIneered Storage
5. ThIs is a potential system to be
utilized for those hazardous wastes
(especially radioactive) for which no
adequate disposal methods exist. Such
a facility would have applicability
until such time as a method for permènent
disposal of these wastes Is developed.
Such a near-ground—surface engineered
storage facility must provide for the
5. This process Is being proposed
for the long-term storage of
high level radioactive wastes. Also,
some low level radioactive wastes will
probably go to engineered storage
facilities.

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Ultimate Disposal
Processes
Description
following: (a) safe storage of the solidified
hazardous wastes for long periods of time, and
(b) retrievability of the wastes at any time
during this storage. The ultimate goal is to
transfer these wastes to a permanent disposal
site when a suitable site Is found
Waste Handling Capability
-4
0
-‘4
6. DetonatIon
6. This Is the process of exploding a quasttty
of waste with sudden violence. Detonation
can be performed by several means which
include thermal shock, mechanical shock,
electrostatic charge, or contact with
incompatible materials. Detonation of a
single waste may be followed by secondary
explosions or fire.
6. This technique is most
coiiinonly applied to explosive
waste materials. However,
several flaimiable waste streams
can also be detonated.

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Appendix E
ON-SITE VERSUS OFF-SITE TREATMENT/DISPOSAL
Assuming that a hazardous waste generator elects to treat or dispose
of his hazardous waste in an environmentally acceptable manner, an important
economic decision that must be made by him is whether a particular waste
stream should be processed on-site or off-site at some regional treatment
facility. In order to make a sound business decision between these options
an industrial manager must consider a number of variables such as the
following: the chemical composition of the particular waste stream; the
on-site availability and unit cost of a satisfactory treatment process;
the quantity of the waste stream; and the distance to and user charge of
the nearest off-site processing facility.
To gain a general insight into the economics of this problem, information
was compiled on eight comonly occurring industrial hazardous waste stream
types, and a mathematical model was formulated. The mathematical model
resulted in economic decision maps for each of the eight industrial waste
categories. (Nine decision maps are attached, because two maps are
included for heavy metal sludges.)
As a result of this analysis, it was concluded that economic considerations
favor the off-site treatment and disposal of seven out of the eight waste
stream types examined. Only in the case of dilute aqueous heavy metals
(Figure E-9) is the strategy of on-site treatment more economical.
The decision map for concentrated heavy metals (Figure E-l) is typical.
The following discussion will identify and interpret, point by point, those
aspects of the map that are considered significant.
Point A on the map represents data collected for a sample of actual
waste sources. This point is defined by the mean separation between sources*
and the mean source size (size as measured by waste stream volume). The
position of point A on the map shows whether the on-site or off-site processing
alternative is economically preferable. Here Point A lies comfortably
within the OFF-SITE region of the map, and off-site processing of wastes
collected from multiple sources is the most logical choice.
The vertical lines corresponding to the smallest and largest sources
in the sample are also sh n for perspective. For each of the stream types
an attempt was made to include the largest single producer of the waste
in the country.
* By “mean separation between sources” is meant the average distance between
some waste sources actually found within a particular region.
108

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Two other points on the map are of interest. Point B defines the
separation between sources that would be required if on-site processing
is to be feasible, assuming no change in the sample mean. For concentrated
heavy metals, this change-of-strategy separation distance is 360 miles
(580 kilometers) compared to the mean value of 81 miles (131 kilometers).
Point C defines the source size at which on-site processing becomes
feasible for sources separated by the sample mean separation. For
concentrated heavy metals, this size is 16 million gallons per year (gpy)
(61 million liters), compared to the sample mean of 325,000 gpy (1.2 million
liters) and a sample maximum of 950,000 gpy (3.6 million liters). Clearly,
off-site processing is preferable for concentrated heavy metal wastes.
A mean volume concentrated heavy metals waste producer would have to be
nearly 400 miles (640 kilometers) from any other similar waste producer
before on-site treatment becomes attractive.
Examining the succeeding eight decision maps (Figures E-2 through
E-9), it becomes apparent that each is different because each particular
waste stream has its own cost characteristics as a result of different
treatment and/or disposal requirements. Only in the case of dilute heavy
metals (Figure E-9) is the above-defined Point A within the ON-SITE region
of the map. Accordingly, the average generator of dilute heavy metal
wastes would logically choose on-site treatment.
Development of the model on which the decision maps are based may
be found in Reference thirty—Six. Included among other important results
of that particular study are discussions of location and spacing of
regional treatment facilities.
109

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Largest Source
OFF SITE PROCES5IN( OF
COLLECTED WASTES
Legend: Numbers in parentheses tre
metric units, and those
without parentheses are
English units.
10,000,000 100,000,000
(37,853,000)
Source Size (gallons or liters per year)
1)
1000
(1609)
100L
(161)
10
(16)
(1.6)1
10,000
(37,853)
I ON-SITE PROCESSING
A ___ ___ ___ ___
Smallest Sàurce
Mean Source
I
I I
I 1
L L.iir 1. $ I
100,000
(378,530)
I,
1,000,000
(3,785,300)
(378,530,000)
Figure E-l Decision Map Concentrated Heavy Metals

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1.000 .
(1609)
(161 I
1
10
(16E
1 Smallest Søurce
I
(1.6)1L I
10,000 100,000
(37,853) (378,530)
1,000,000
(3,785,300)
Largut$durce
10,000,000
(37,853,000)
Legend: .Nunib rs in. ar€ itheses.
are 11 etric unit , and those
withc t parent1 s s ae
Engl sh tu ,tts,
100,000,000 1,000,000,000
(378,530,000) (3,785,300,000)
Source Size (gallons or liters per year)
Figure E-2 Dilute Metals With Organic Contamination
I
I
I
1
I
B
ON-ShE. PROCESSING
1
4)
C
A
Mean So rcg
QIF-SITE PROCESSING

-------
I
I
1.000
(1609)
U)
w
(161)0
‘-4
.
U)
0
U)
—‘ 10.4
—. (16)
4J
w
U)
S mallest Source
(1.6) 1
1,000
10,000
100,000
(1609)
(37,853)
(378,530)
Mien Source
1,000,000
(3, 785 , 300)
Source Size (gallons or liters per year)
F ’,,
Largest Source
t 1 egend: Numbers in
parentheses are metric
units, and those without
parentheses are English
units.
10,000,000
(37, 853,000)
ON-SITE TREATMENT
C
I
OFV-SITE TREATMENT
Figure E-3 Asphalt Encapsulation of Heavy Metal Sludges

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I
Smallest Source
I
Largest Source
H
OFF-SITE TREATMENT
OF COLLECTED WASTES
Legend: Numbers in parentheses
are metric units, and
those without parentheses
are English units.
10,000 100,000
1,000,000
(37,853) (378,530)
(3,785,300)
10,000,000
(37,853,000)
Source Size (gallons or liters per year)
(0
I )
ON-SITE TREATMENT
C
1,000
(1609)
1,000
(1609)
‘——4 - -—— -- - —
A
Mean Source
100.
(161)
10
(16)
(1.6) 1
Figure E-4 Cement Encapsulation of Heavy Metal Sludges

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(1609)
U)
14
I
o 100
(161)
.
U)
0
U)
10
(16)
•rl
04
w
U)
(1.6) 1 1:
I ,
1
I
Smallest Source
Legendz Numbers n parentheses
öre metric units, and
I those witholit paren-
I theses are English
I , I
1,000 10,000
(1609) (37,853)
Source Size (gallons or liters per year)
Mean Source
100,000
(378, 530)
I
Largest Source
OFF•SITE TREATMENT
units.
1,000,000 10,000,000 100,000,000
(3,785,300)
(37,853,000)
ON-SITE TAEATMENT
I
A
— — - F
I
(378,530,000)
Pigure E-5 Concentrated Cyanides

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a)
10,000
(37,853) H
1,000
(1609)
100
(161)
(16) 10 L
1,000
(1609)
Smallest Source
10,000
(37,853)
I I
‘I,
Mean Source
100,000
(378,530)
Largest Source
Ii
1,000,000
(3,785,300)
Source Size (gallons or liters per year)
Legend: Numbers, ir parentheses
are metric unitS,
thQ e without parentheses
are English ur its
100,000.000
(378,530,000)
10,000,000
(37,853,000)
I
B
ON ITE TREATMENT
I A
I
— — - ——-— — - - - -
OFF-SITE TR:EATMENT
OF COLLECTE.P WASTES
Figure E-6 Liquid Chlorinated Hydrocarbons

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‘ (161)
m 10
(16)
4 )
U)
0
(16) 1
1,000
(1609)
I.
Smallest Source
Legenth
I,
10,000
(37,853)
Numbers th parentheSes are
metric units, a d those
without parentheses are
English units.
100,000
(378,530)
Source Size (gallons or liters per year)
Figure E-7 Dilute Cyanides
LargestSource
H
1,000,000
(3,785, 300)
oTER ArMEN ’r
10,000,000
37,853,000)
I
I
I
I
B
ON-SITE TREATMENT
I
I
A
Mean Source

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(1)
4 - I
a)
0
U)
a)
‘-.4
.
U)
a)
0
0
U)
a)
4 1)
4)
-a
-I
• ‘•J - -I
a)
4’)
10,000
(37,853)
1,000
(1609)
100.
(161)
(16) 10
10,000
(37,853)
Smallest Source
at 1,000 gallons per year
100,000
(378,530)
I
I
I
Largest Source
1,000.000
(3,785,300)
OFF-SITE TREATMENT
OF COLLECTED WASTES
10,000,000
(37,853,000)
N nnber in parentheses are
metric units,andt1 ose without
parentheses are English ur i s.
100,000,000
(378,530,000)
1.000,000.000
(3,785,300,000)
Source Size (gallons or liters per year)
rrr
I 4
-j ’ ’:!: .1 •t1:T1t —- - ! 1

T:i L.i : H - - -
I
ON SITE TREATMENT
L
E1• .I i-:
A
Mean Source
---4 - --
tegend:
Figure E-8 Chlorinated Hydrocarbon and Heavy Metal Slurries

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1,000
(1609)
ON SITE PROCESSING
a)
I
(i u IIT IIIIIIIIIIIIIiiiiii A
0
to
0)
U)
0)
ource
C)
0
U)
MearsSourte
—j
10
a)
# (16) 1 SmaliestSource
“ -I
4)
C t, S
Legend: Nun bers in parenthe8es are
metric units, and those
I wititout parentheses are
U)
English units.
(1.6) 1
1,000 10,000 100,000 1,000,000 10,000,000 100,000,000
(1609) (37,853) (378,530) (3,785,300) (37,853,000) (378,530,000)
Source Size (gallons or liters per year)
Figure E-9 Dilute Heavy Metals

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Appendix F
SUMMARY OF THE HAZARDOUS WASTE
NATIONAL DISPOSAL SITE CONCEPT
In the course of investigating the concept of “National Disposal
Sites “ for hazardous wastes as mandated by Section 212 of the Solid
Waste Disposal Act (P.L. 89-272 amended by P.L. 91-512), important
and relevant information was developed. Appendices B and D, respec-
tively, provide a list of hazardous wastes subject to treatment at
such sites, and summaries of current methods of treatment and dis-
posal. This Appendix summarizes the findings related to: site
selection, methods and processes that are likely to be used at a
typical site, and the costs for developing and maintaining such sites.
Reference one contains the detailed analyses performed and the rationale
for this information.
Siting of Hazardous Waste Treatment and Disposal Facilities
The general approach to the site selection process was to first
regionalize the conterminous United States into 41 multi-county regions.
Spheres of influence for major industrial waste production areas,
which are closely related to hazardous waste production areas, served
as the basis for regional delineation (see Table F-i). Thirty-six
waste treatment regions were identified, based upon the distance from
the 41 major industrial waste production centers, and are shown on
Figure F—l. A distance of about 200 miles (322 kilometers) in the
East and 250 miles (402 kilometers) in the West was selected as the
maximum distance any treatment site should be from the industrial waste
production centers in a given subregion. Some of the regions do not
contain an industrial waste production center; however, their boundaries
are defined by surrounding regions containing waste production centers.
No region was generally permitted to cross any major physiographic
barrier. Notably, the regions are smaller in the East than In the West.
Criteria for site selection were defined with the major emphasis
placed on health and safety, and environmental considerations. It
was recognized early that two general types of sites would need to be
identified: waste processing plant sites, and long-term hazardous
waste disposal/storage sites. Site selection criteria and numerical
weightings are presented in Table F-2.
Based on the site selection criteria, a ranking, screening, and
weighting procedure was developed and applied to all counties located
in the 36 regions which cover the country. The county-size areal
unit (3,050 counties in the conterminous U.S.) appeared to be one of
119

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manageable size for the survey. The output listing of all 3,050
counties, grouped by regional ratings is contained in Reference one
and is too voluminous for inclusion here. This listing allows for
the orderly aid rational selection of counties within each region,
for site-specific reconnaissance, and for later detailed field studies
that would be required in order to prove out the feasibility of a
candidate site. From the total list that rates and ranks all counties,
74 appear to be potentially the best areas for locating hazardous
waste treatment/disposal sites. These are presented in Table F-3.
In addition, existing or potential Federal and State hazardous waste
treatment and disposal sites were identified. Selected examples of
these are presented in Table F-4. It should be noted that these are
candidate sites; the suitability of a particular site can only be
determined by additional field studies, field testing, and technical
analyses of the data.
Hazardous Waste Management Methods and Costs
The approach used In this phase of the study involved development
of a Mmodelu facility capable of processing a wide variety of hazardous
wastes (excluding radioactive wastes or chemical warfare agents generated
or stored at AEC or DOD installations). Conceptual design and cost
estimates were prepared for a complete waste management system to
process and dispose of the wastes. In addition to treatment and dis-
posal, peripheral functions such as transportation, storage, and
environmental monitoring were also considered.
The basic objective of waste treatment at a hazardous wastes
processing facility is the conversion of hazardous substances to forms
which are acceptable for disposal or reuse. Since the majority of
hazardous waste streams are complex mixtures containing several chemi-
cal species, treatment for removal and/or conversion of certain non-
hazardous substances from the waste stream will also be required In
order to comply with pollution control regulations. In a number of
instances, treatment for the nonhazardous substances will dictate the
type of process used and will entail the most significant operational
costs (e.g., acid neutralization).
Broad treatment capability In a central processing facility will
permit the processing of many nonhazardous wastes which could give the
facility the advantage of economy of scale. In order to maintain a
competitive position in the waste processing field In the case of a
privately operated facility, It is anticipated that all wastes which
can be processed with some return on investment will be accepted. It
is possible that the volume of nonhazardous wastes will exceed the
volume of hazardous wastes, perhaps by wide margins, in many areas.
Inclusion of nonhazardous wastes processing also increases the
opportunities for resource recovery (e.g., recovery of metals, oils,
and solvents).
120

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It must be emphasized that the model facility developed in this
study was primarily designed for processing hazardous wastes. There-
fore, processing facilities designed for both hazardous wastes and
norihazardous wastes may be different in many respects. A number of
factors will dictate individual design variations for a given facility.
Foremost will be the volumes and types of wastes, both hazardous and
nonhazardous, that will be received for processing. One facility may
require many different processes whereas another may require only one.
Furthermore, processes selected for the model facility are not intended
to be all-Inclusive. A wide variety of processes, In addition to those
selected for the model facility, is available to meet the needs of a
particular location.
Description of Model Facilities
Hazardous Wastes Processing Facility . The model hazardous wastes
procesilng racility incorporates the various functions related to
waste treatment and disposal at one central location. The facility Is
basically a chemical processing plant which has design features for
safe operation in a normal industrial area. Effluents discharged from
the facility will be limited to those which meet applicable water and
air standards. Local solid waste disposal will be limited to non-
hazardous wastes which are acceptable for burial at a conventional
landfill. The conventional landfill may be located adjacent to the
processing facility or a short distance away. In general, nonhazardous
waste brines resulting from hazardous waste treatment will be disposed
by ocean dumping where appropriate to avoid potential quality impair-
ment of fresh water sources. Land disposal of these brines is a
potential alternative method which Is less desirable and which will be
used only in arid regions and even there infrequently. All such dis-
posal operations will be in accordance with applicable local, State,
and Federal standards.
In order to accomplish treatment and disposal objectives, the
facility will also contain equipment and structures necessary for
transporting, receiving, and storing both wastes and raw material.
Another important feature will be a laboratory which provides:
(1) analytical services for process control and monitoring of efflu-
ent and environmental samples; and (2) pIlot scale testing services
to assure satisfactory operation of the processing plant. The latter
normally is not required in a conventional chemical processing plant,
but due to the highly variable nature of the waste feed In this case,
pilot scale testing Is considered essential.
Hazardous Wastes Disposal Facilijy . For purposes of the mOdel
the hazardous wastes disposal facility will consist of a secure”
landfill and the appropriate equipment and structures necessary to
carry out burial and surveillance of the hazardous solid wastes.
Special measures are to be taken during backfilllng to minimize
121

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water infiltration. It is possible that low level radioactive burial
sites currently used in arid regions of the western United States
could also be used with appropriate segregation, for disposal of the
hazardous solid wastes.
Process Selection . Conceptual design objectives for the model
facility included broad treatment capability to permit processing of
all hazardous wastes of significant volume generated across the
country. Important process selection criteria include demonstrated
applicability to the treatment and disposal of existing hazardous
wastes and flexibility to handle a wide variety of different waste
streams.
The objectives of waste processing at the model facility are the
removal of hazardous and polluting substances and/or conversion of
these substances to forms which are acceptable for disposal or reuse.
Based upon the hazardous wastes identification portion of this study
described in Section 2 and In Appendix B, it was determined that in
order to accomplish these objectives the model facility should include
treatment processes for:
1. Neutralization of acids and bases
2. Oxidation of cyanides and other reductants
3. Reduction of chromium-6 and other oxidants
4. Removal of heavy metals
5. Separation of solids from liquids
6. Removal of organics
7. Incineration of combustible wastes
8. Removal of ammonia
9. Concentration of waste brines
Processes selected for inclusion In the model facility are presented
In Table F-5. Also, Appendix 0 describes the major characteristics
of these processes. A conceptual flow diaqram . which integrates the
various treatment steps in modular form (Illustrated In Figure F-2),
was developed for the model hazardous waste facility. The flow pattern
represents that normally expected, and provides for additional piping
to permit alterations when necessary.
Cost Estimates . Design capacities, capital, and operating costs
for typical small, medium, and large size processing facilities are
122

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sumarized in Tables F—6, F .-7, and F-8, respectively. The costs include
estimates for land, buildings, laboratory offices, and auxiliary equip-
ment. It should be noted that these cost data are based on preliminary
estimates which have been developed from a nunber of basic assumptions,
and are only intended to indicate the norm of a range of costs. Table ‘F-9
identifies in sequence those basic assumptions that have been utilized
to arrive at the number, fixed capital and operating costs of large,
medium, and small hazardous waste treatment/disposal facilities. This
Information was then utilized to develop the configuration for the scenario of a
hazardous waste management system cited In Section 4.
A more detailed comparative cost analysis that identifies and sumarizes
capacities, fixed capital, and operating costs associated specifically with
treatment facilities has been developed In Table F-b. These data were
utilized in developing the cost aspects of the system scenario.
123

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Table F-i
Indus tn al Waste Production Centers
1. Seattle, Tacoma, Everett, Bellingharn, WA
2. Portland, OR; Vancouver, Longview, WA
3. San Francisco Bay Area, CA
4. Ventura, Los Angeles, Long Beach, CA
5. San Diego, CA
6. Phoenix, AZ
7. Salt lake, Ogden, UT
8. Idaho Falls, Pocatello, ID
9. Denver, CO
10. Santa Fe, Albuquerque, fil
ii. El Paso, TX
12. Fort Worth, Dallas, Waco, TX
13. Austin, San Antonio, Corpus Christi, TX
14. Houston, Beaumont, Port Arthur, Texas City, Galveston, TX
15. Oklahoma City, Tulsa, Bartlesville,OK
16. Wichita, Topeka, Kansas City, KS
17. naha, Lincoln, NB; Des Moines, IA
18. Minneapolis, St. Paul, Duluth, MN
19. Cedar Rapids, MI; Burlington, Dubuque, IA; Peoria, IL
20. St. Louis, MO; Springfield, IL
21. MemphIs, TN
124

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Table F-i (Continued)
22. Shreveport, Baton Rouge, New Orleans, LA; Jackson, MS
23. Mobile, Montgomery, AL; Tallahassee, FL; Biloxi, Gulfport, MS;
Columbus, GA
24. Huntsville, Birmingham, AL; Atlanta, Macon, GA; Chattanooga,
Nashville, TN
25. Louisville, Frankfort, Lexington, KY; Evansville, IN
26. Albany, Troy, Schenectady, NY
27. Indianapolis, IN; Cincinnati, Dayton, OH
28. Chicago, Kankakee, IL; Gary, South Bend, Hamond, Fort Wayne, IN
29. Midland, Saginaw, Grand Rapids, Detroit, Dearborn, Flint, MI;
Toledo, OH
30. Columbus, Cleveland, Youngstown, Akron, 01- ?
31. Pittsburgh, Johnstown, Erie, PA
32. Charleston, WV; Portsmouth, Norfolk, VA
33. Charleston, SC; Savannah, Augusta, GA
34. WInston-Salem, Raleigh, Greensboro, Charlotte, NC
35. Baltimore, M D
36. PhIladelphia, Allentown, Harrisburg, PA; Camden, Elizabeth, NJ;
Wilmington, DE
37. New York, NY; Newark, Paterson, NJ
38. Buffalo, Rochester, Syracuse, Watertown, NY
39. Boston, MA
40. Orlando, Tampa, Miami, FL
41. Little Rock, Pine Bluff, Hot Springs, AR
125

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• ... •1 •. - -
•
‘: ! •.. \‘
.—. .
- I .—.. .. • ‘.•
T
5’ ’ •. . ..I • -.
— .; .•.— _ ._
- -.. ‘ S
• .. — ‘-S ‘ ••
-•-•• 5J
• — ‘“:.
,1
Figure F-i Site Selection Regions
1S
- ‘ . 5 .
•: ‘‘
i ‘9?’--
1*
- . 5- - -
‘S
‘5,5.
‘S S.
I • ‘‘
S\ • .
—I
IC
‘ ‘I
- -•
V
- .1

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Table F-2
Site Selection Criteria
General Criteria We htin
o Earth Sciences 31
o Geology
o Hydrology
o Soils
o Climatology
Transportation 28
Risk
o Economics
O Ecology 18
o Terrestrial Life
o Aquatic Life
O Birds and Wildfowl
O Human Environment and Resources Utilization 23
O Demography
o Resources Utilization
o Public Acceptance
100

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Table F-3
Potential Waste Treatment and Disposal Sites
STATE COUNTY
Alabama Surnter*
Arizona Yuma
Dallas
California Fresno
I nyo
Kern*
Ventura
Colorado Weld
Connecticut Hartford
Florida Alachua
Georgia 000ley*
Iowa Howard
Illinois Jasper
Vermil lion
Livingston*
Ogle
Indiana Jackson
Kansas Ellsworth
Kentucky Franklin
Maryland Carroll
Massachusetts Franki j *
Worcester
Mississippi Lincoln
128

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Table F-3 (Continued)
STATE COUNTY
Michigan Isabella*
SM awassee
Missouri Audrain
Montana Custer
Nebraska Kearney
Nevada Nye*
Pershing
Washoe
New Jersey Sussex
New Mexico Eddy
Quay
San Juan
New York Albany
Onondaga
Otsego
Steuben
Wyoming
North Dakota Grand Forks
Oklahoma Atoka
Custer
Kay
Ohio Darke
Carroll
Wayne
Oregon Deschutes
Pennsylvania Clinton
Montgomery
York*
South Carolina Barnwell
GreenwoOd
129

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Table F-3 (Continued)
STATE COUNTY
Tennessee Gibson
Montgomery
Texas Bell
Erath*
Gillespie
Grimes
Harrls*
Haskell
Kendall
Polk
Sutton
Utah Tooele
Virginia Brunswick
Caroline
Fluvana
Pittsyl vania
Washington Benton
Lincoln
West Virginia Doddridge
Wyoming Campbell
Laramie
*Denotes potential for large size processing facility.
130

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Table F-4
Existing and Potential Hazardous Waste Treatment and Disposal Sites
(FEDERAL AND STATE)
Existing Sites Operated by Federal Agencies
U SAEC
Hanford Works, Benton County, Washington
Savannah River Plant, Aiken County, South Carolina
National Reactor Testing Station, Bingham County, Idaho
Nevada Test Site, Nye County, Nevada
Oak Ridge, Anderson County, Tennessee
Los Alamos Scientific Laboratory, Los Alamos County,
New Mexico
Pantex Plant, Randall County, Texas
Rocky Flats Plant, Jefferson County, Colorado
Fernald, Butler/Hamilton Counties, Ohio
DOD
Edgewood Arsenal, Maryland
Pine Bluff Arsenal, Arkansas
Rocky Mountain Arsenal, Colorado
Tooele Army Depot, Utah
Umatilla Army Depot, Oregon
Anniston Army Depot, Alabama
Pueblo Army Depot, Colorado
Newport Army Ammunition Plant, Indiana
Lexington Bluegrass Army Depot, Kentucky
State Licensed Radioactive Waste Sltes*
Morehead, Kentucky
Beatty, Nevada
Hanford Works, Washington
West Valley, New York
Barnwell, South Carolina
*The Sheffield, Illinois site Is directly licensed through USAEC,
but is not operated by the USAEC.
131

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Table F-4 (Continued)
Representative Coninercial Radioactive Waste Burial Site Characteristics
a. Beatty, Nevada Site
Background
Ownership of site
Population - density in area
Location re towns and cities
Area of (1) site; (2) controlled
acres
Comunicatlons
Precipitation (In.) (centimeters)
Site Characteristics
State of Nevada, leased to NECO
Desert, virtually uninhabited
About 12 ml (19.3 kilometers)
southeast of Beatty
(1) 80; (2) desert, not controlled
Good; hwy U.S. 95
2.5-5.0(6.35—12.7 cm)/yr
Drainage
Bedrock depth and materials (est
Surficial material - depth; types
Groundwater - depth; slope
Land and water use downstream
General soil characteristics
Operation - Eguij:m nt and Methods
Adequate
575 +ft (175 meters); various
sedimentary and metamorphic
“ 575 ft (175 meters) alluvial
clay, sand, etc.
275-300 ft (84-91.5 meters);
SE ’ 3O ft/mi (5.67 meters/kilo-
meters)
Very little, desert conditions
Semi—arid desert; deep soil
Monitoring lnstitmmnts and devices
Waste handling machinery
Trenches - (1) dImensions; (2)
design (3) pumped water?
Waste handling - (1) transport by
company; (2) processing; (3)
burial procedures
14 survey instrs; film, air
monitors; etc.
Tank truck; trailer trucks;
dozer; 35-T crane
(1) 650 (19&n) x 50 (15.2m) x
depth 20 (6.lm)ft; (2) usual
design, I.e., drain to sump,
4 ft (1. ) backfill; (3) no
water collected
(1) yes; (2) liquids solidified;
(3) sp. flu. mat. spaced at
bottom, slit trench for high-
activity materials
132

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Table F-4 (Continued)
b. Morehead, Kentucky Site
ac kground
Ownership of site
Population - density in area
Location re towns and cities
Area of: (1) site; (2) controlled
acres (hectares)
ColTinunicati ons
Precipitation (in.) (centimeters)
Site Characteristics
State of Kentucky, leased to
N ECO
Rural, sparse (Maxey Flats)
10 mi (16 hectares) northwest
of Morehead
(1) 200 (81 hectares); (2) 1000
(405 hectares)
Fair; state hwy N and S
46 (117 cm) /yr (heavy storms)
Drainage
Bedrock depth and materials (est)
Surficial material - depth; types
Groundwater - depth; slope
Land and water use downstream
General soil characteristics
Well drained
50—75 ft (15.25—22.8 meters)
shale, sandstone, siltstone
50-75 ft (15.25—22.8 meters)
shale, clay, siltstone
35-50 ft (10.7-15.25 meters)
(“perched” 2-6 ft [ 0.61-1.83
meters)); erratic
Very little nearby, distant
(no data)
Very impermeable; good soil
sorption
Monitoring instruments and devices
Watte handling machinery
Trenches - (1) dimensions; (2) design;
(3) water pumped?
Waste handling - (1) transport by
company; (2) processing; (3)
burial procedures
Essentially same as at Beatty
Usual - crane; dozer; forklifts;
etc .
(1) 300 (9.15m) x 50 (l5.25m) x
depth 20 (6.lm) ft; (2) usual
design, sump; (3) yes
(1) and (2) same as Beatty (both
NECO); (3) per “Radiation Safety
Plan” (NECO)
‘.1,
Operation - Equipment and Methods
133

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Table F-4 (Continued)
C. Hanford, Washington Site
Background
.nership of site
Population - density in area
Location re towns and cities
Area of (1) site; (2) controlled
acres
Coninunications
Precipitation (in.) (centimeters)
Site Characteristics
State of Washington, leased
to NECO
No resident, inside AEC plant
25 mi (40.2m) north of Richiand
(1) 100 (40 hectares); (2) 1000
(400 hectares) state owned
Good, AEC Hanford reservation
6—8 (15-20 cm) /yr.
Drainage
Bedrock depth and materials (est)
Surficial material — depth; types
Ground water—depth; slope
Land and water use do wistream
General soil characteristics
Qperation - Equipment and Methods
Well drained
250—450 ft (76-137m); basalt
150—350 ft (47—10.7m); silty
sand, gravel, clay
240 ft (73m); N and E “. 15—35 ft/
ml (2.8-6.6 meters/kilometers)
Columbia River - all uses
Little precipitation; deep dry
soil
Monitoring instruments and devices
Waste handling machinery
Trenches — (1) dImensions; (2) design;
(3) water pumped?
Waste handling - (1) transport by
company; (2) processing; (3) burial
procedures
As licensed - survey lnstrs,
film, counters
Usual - crane, shovel, dozer,
lifts, etc.
(1) 300 (92m) x 60 (l8m)
25 ft (7.6m); (2) usual
(3) no water collects In
(1) yes, 95%; (2) lIquids
solidified; (3) sp. flu, mat.
spaced, separate trench for
ion-exchange resins
X depth
design;
s ump
134

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Table F-5
Process Selected For Inclusion In
Model Hazardous Wastes Processing/Disposal Facility
Treatment Processes Disposal Processes
Neutralization Ocean Dumping
Precipitation Landfill
Oxidation—Reduction
Flocculation-Sedimentation
Filtration
Ammonia Stripping
Carbon Sorption
Incineration
Evaporation
135

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Figure F-2
Conceptual Modular Flow Diagram
ATMOSPHERE

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Table F-6
Preliminary Cost Estimate Summary For
Small Size Processing Facility
CAPACITY: 25,000 gpd (94,600 liters Aqueous Waste Treatment
15 tons (13,6 metric tons) /day Incineration
260 day/year Operation
TOTAL FIXED CAPITAL COST: $9,300,000
MODULAR CAPITAL AND OPERATING COST: AQUEOUS WASTE TREATMENT
Fixed Daily Ave. Cost Per 1000
- Module Capital Cost,$ Operating Cost,$ Gal(3,785 liters),$
Receiving & Storage 1,262,000 1,881 66.20
Ammonia Stripping 298,700 461 18.40
Chemical Treatment 1,827,300 3,298* 150,50
Liquid—So lids
Separation 3,460,000 3,888* 80.10**
Carbon Sorption 363,000 758* 17.50
Evaporation 198,000 635* 14.60
Rounded Totals 7,410,000 10,900 347.00
MODULAR CAPITAL AND OPERATING COST: INCINERATION
Fixed Daily Ave. Cost
Nodule Capital Cost,$ Operating Cost,$ Per ton,$
Incinerator 1,880,000 3,200 213.00
Scrubber Waste—
water Treatment (18,450 gpd) 185.00
(70,000 liters) __________
Total 398.00
* Includes processing cost for incinerator, scrubber wastewater.
** Excludes processing cost for clarifying incinerator scrubber
was tewater.
137

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Table F-7
Preliminary Cost Estimate Summary For
Medium Size Processing Facility
CAPACITY: 122,000 gpd (462,000 liters) Aqueous Waste Treatment
74 tons (67 metric tons) /day Incineration
260 day/year Operation
TOTAL FIXED CAPITAL COST: $24,070,000
MODULAR CAPITAL AND OPERATING COSTS: AQUEOUS WASTE TREATMENT
Fixed Daily Ave. Cost Per 10
Module Capital Cost,$ Operating Cost,$ Gal(3785 liters )
Receiving & Storage 3,270,000 6,424 46.40
Ammonia Stripping 773,800 952 7.80
Chemical Treatment 4,734,000 11,307* 84.70
Liquid-So 1 ids
Separation 8,963,700 9,516* 39.60**
Carbon Sorption 941,000 1,578* 7.40
Evaporation 514,000 2,173* 10.20
Rounded Totals 19,200,000 32,000 196.00
MODULAR CAPITAL AND OPERATING COSTS: INCINERATION
Fixed Daily Ave. Cost
Module Capital Cost,$ Operating Cost,$ Per ton,S
Incinerator 4,873,000 7,000 94.60
Scrubber Waste—
water Treatment (90,000 gpd) 80.60
(341,000 liters)
Total 175.00
* Includes processing cost for incinerator scrubber wastewater
** Excludes processing cost for clarifying incinerator scrubber
wastewater
138

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Table F-8
Preliminary Cost Estimate Sumary For
Large Size Processing Facility
CAPACITY: 1,000,000 gpd(3,785,300 liters) Aqueous Waste
Treatment
607 tons (550 metric tons)/day Incineration
260 day/year Operation
TOTAL FIXED CAPITAL COST: $86,000,000
MODULAR CAPITAL AND OPERATING COSTS: AQUEOUS WASTE TREATMENT
Fixed Daily Ave.Cost Per 1000
Module Capital Cost,$ Operating Cost,$ Gal(3785 liters ) ,$
Receiving & Storage 11,543,000 38,150 33.60
inmonia Stripping 2,731,500 3,180 3.18
Chemical Treatment 16,710,600 60,630* 53.83
Liquid-Solids
Separation 30,915,700 34,687* 17.18
Carbon Sorption 3,322,000 6,290* 3.62
Evaporation 3,413,000 15,947* 9.16
Rounded Totals 68,600,000 159,000 121
MODULAR CAPITAL AND OPERATING COSTS: INCINERATION
Fixed Daily Ave. Cost
Module Capital Cost,$ Operating Cost,$ Per ton,$
Incinerator 17,201,700 27,374 45.10
Scrubber Waste—
water Treatment (738,000 gpd) 55.70
(2,800,000 liters) _________
Total 101.00
* Includes processing cost for incinerator scrubber wastewater.
** Excludes processing cost for clarifying incinerator scrubber
wastewater.
1 39

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Table F-9
Basic Assumptions Utilized for Developing the
Hazardous Waste Management System Scenario
Nunter Basic Assumptions
All hazardous waste will be treated and disposed of in an
environmentally acceptable manner.
2 All hazardous wastes will be treated prior to being disposed
of at designated sites to minimize hazard and volume of wastes
deposited on land.
3 Treatment and disposal facilities will be dedicated to hazardous
wastes. Treatment facilities should have those capabilities
indicated in Tables F-6, F-7, and F-8.
4 Certain types and quantities of hazardous wastes will, be treated
on-site (at the source) and others at off-site facilities.
o The estimated total amount of hazardous wastes to be treated!
disposed of is 1.0 X 1Q 7 tons (9 X 106 metric tons) per year.
Approximately 4.0 X 10° tons (3.6 106 metric tons) are inor-
ganic and 6.0 X 106 tons (5.4 X 100 metric tons) are organic.*
5 EPA economic studies indicate that on-site treatment facilities
will be small plants treating primarily dilute aqueous acidic
toxic metal wastes which constitute approximately 15 percent by
weight of all hazardous wastes. Small on-site facilities will be
capable of neutralizing wastes and precipitating toxic metals
from the wastes, but will produce a toxic residue which will
require further treatment at off-site facilities.
o Small facilities will have a capacity of 2.94 X io tons (2.6 X
b 4 metric tons) per year. Approximately 51 small on-site facili-
ties will e required to treat the estimated 1.5 X 106 tons
(1.36 X 100 metric tons) per ypar. Approximately one-third of
wastes treated on-site [ 5 X l0 tons (4.5 X i0 5 metric tons) per
year] will be shipped to off-site facilities for further treatment.
6 To achieve economies of scale, off-site treatment facilities will
be large or medium size treatment plants.
o Approximately 9.0 X 106 tons (8.2 X 106 metric tons) per year
will be processed at off-site facilities.
o Large facilities will have a capacity of 1.33 X 106 tons (1.2
X 10° metric tons) per year, and medium facilities a capacity o
1.62 X 10 ’ tons (1.47 X i0 5 metric tons) per year.
* EPA Contract No. 68-01-0762.
140

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o System variation studies indicate that the configuration
contining least cost and adequate geographical distribution
consists of 5 large and 15 medium size facilities. Therefore,
large oft-site treatment facilities will process approximately
6.5 X 10 tons (6.0 X 106 metric tons) per year and medium
facilities will process approximately 2.5 X 100 tons (2.27 X 10
metric tons) per year.
7 Current treatment technology does not allow complete neutralization/
detoxification of all hazardous wastes. It is estimated that
treatment residues constituting 2.5 percent of the incoming waste
[ 225,000 tons (200,000 metric tons) per year] will still be
hazardous .
O Hazardous residues resulting from treatment facilities will
be disposed 0 f in secure land disposal sites.
o The most convenient location for secure land disposal sites
is in association with the large treatment facilities. Therefore,
five large secure disposal sites would initially be required.
O Hazardous wastes generated at other off-site treatment facilities
would also be disposed of at the five large secure disposal sites.
* EPA Contract No. 68-01-0762.
141

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Table F—b
Capacities and Costs of Hazardous Waste Treatment Facilities Assumed In Hazardous Waste Management System Scenario
OFF-s IT
E
CM-SITE
Large Facility Medium Facfllty Small Facility Smell
FaclTity Total Costs
c1
(1) Processing Capacity, gal/day (liters/day) aqueous wastes 1,000,000 122,000 25,000 25,000
(3,BOQ,QQQ) (462,000) (95,000) (95,000)
(2) 0 9lb/g l, (1) expressed as tons/day (metric tons/day) 550 113 113
(4,080) (498) (102) (102)
(3) Processing Capacity, tons/day (metric tons/day) combustible wastes 607 74 15 —
(550) (67) (14) —
(1) Total Processing Capacity, tons/day (metric tons/day) 5,107 624 128 113
(4,627) (565) (116) (102)
(5) Total Processing Capacity, tons/ year (metric tons/year) [ 1] 1,330,000 162,000 33,300 29)400
(1,210,000) (147,000) (30,200) (26,600)
Cost
7 Fixed Capital, $ 86,000,000 24,14 )0,000 9,300,000 1,400,000
7 OperatIng Cost, S/day 186,400 39,000 14,100 2,265
8 Operating Cost, 5/yr. [ 2] 48,500,000 10,130,000 3,660,000 589,000
9 Operating Cost, S/yr., with capital write—off [ 3] 57,100,000 12,540,000 4,590,000 729,000
Total Cost
110 Approximate no. of facilities required (4] 5 15 51
11 FIxed Capital, $ million 430 362 71 863
12 Operating Cost, $ million/yr., basis (9) 286 188 37 511
Notes: [ 1) Assuming actual plant operation of 260 days/year.
[ 2] Includes neutralization chemicals, labor,utlllties, maintenance, amortization charges (0 7% interest), insurance, taxes,
and administrative expenses.
[ 3] 10—year straight line depreciation.
[ 4] Based on data from EPA Contract No. 68-01—0762 and EPA system variation analysis.

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Appendix G
PROPOSED
Hazardous
Waste
Management
Act
of 1973
93d Congress,
1st Session
IN THE U.S. SENATE
Bill S. 1086
Introduced by Senator Baker
March 6, 1973
Referred to Committee on Public Works
IN THE U.S. HOUSE OF REPRESENTATIVES
Bill H.R. 4873
introduced by Representative Staggers
for himself
and Representative Devine
February 27, 1973
Referred to Committee
on Interstate and Foreign Commerce
U.S. ENVIRONMENTAL PROTECTION AGENCY
143

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A BILL
To assure protection of public heakh and other living organisms
from the adverse impact of the disposal of hazardous wastes,
to authorize a research program with respect to hazardous
waste disposal, and for other purposes.
1 Bc it enacted by the Senate and House of Representa-
2 lives of the United Slates of America in Coagress assembled,
3 SECTION 1.. This Act may be cited as the “llazardou
4 Waste Management Act of 1973”.
5 FINDINGS AND PURPOSE
6 SEC. 2. (a) The Congress finds—
7 (1) that continuing technologi d progress, im-
8 provement in the methods of manufacture, and abate-
144

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1 merit of air and water pollution has resulted in an
2 ever-mounting increase of hazardous wastes;
3 (2) that improper land disposal and other manage-
4 ment practices of solid, liquid, and semisolid hazardous
5 wastes which are a part of interstate commerce are re-
6 suIting in adverse impact on health and other liV ing OI —
7 ganisms;
8 (3) that the knowledge and technology necessary
9 for alleviating adverse health, environmental, and es—
10 thetic impacts associated with current waste manage-
11 ment and disposal practices are generally available at
12 costs within the financial capacity of those who generate
13 such wastes, even though this kn w1edge and technology
14 are not widely utilized;
15 (4) that private industry has demonstrated its
16 capacity and willingness to develop, finance, construct,
17 and operate facilities arid to perform other activities for
18 the adequate disposal of hazardous and other waste
19 materials;
20 (5) that while the collection and disposal of wastes
21 should continue to be a responsibility of private individ-
22 uals and organizations an d the concern of State, regional,
23 and local agencies, the problems of hazardous waste
24 disposal as set forth above and as an intrinsic part of
145

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1 interstate commerce have become a matter national in
2 scope and in concern, and necessitate Federal action
3 through regulation of the treatment and the disposal of
4 the most hazardous of these wastes, and through techni-
5 cal and other assistance in the application of new and
6 improved methods arid processes to provide for proper
7 waste disposal practices and reductions in the amount of
8 waste and unsalvageable materials.
9 (b) The purposes of this Act therefore are—
10 (1) to protect public health and other living orga-
nisms through Federal regulation in the treatment and
12 disposal of certain hazardous wastes;
13 (2) to provide for the promulgation of Federal
14 guidelines for State regulation of the treatment and
15 disposal of hazardous wastes not subject to Federal reg-
16 ulation;
17 (3) to provide technical and other assistance to
18 public and private institutions in the application of ef-
19 ficient and effective waste management systems;
20 (4) to promote a national research program relat-
21 ing to the health and other effects of hazardous wastes
22 and the prevention of adverse impaets relating to health
23 and other living organisms.
146

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DEFINITIONS
2 SEC. 3. When used in this Act:
3 (1 ) The term “Administrator” means the Administra-
4 for of the Environmental Protection Agency.
5 (2) The term “State” means a State, the District of
6 Columbia, and the Commonwealth of Puerto Rico.
7 (3) The term “waste” means useless, unwanted, or
8 discarded solid, semisolid or liquid materials.
9 (4) The terni “hazardous waste” means any waste or
10 eombinatioii of wastes which pose a substantial present or
11 potential hazard to human health or living organisms because
12 such wastes are nondegradable or persistent in nature or
13 because they can be biologically magnified, or because they
14 can be lethal, or because they may otherwise cause or tend
15 to cause detrimental cumulative effects.
16 (5) The term “secondary material” means a material
17 that is or can be utilized in place of a primary or raw
18 material in manufacturing a product.
19 (G) The term “generation” means the act or process
20 of producing waste materials.
21 (7) The term “storage” means the interim contain-
22 ment of waste after generation and prior to ultimate disposal.
23 Containment for more than two years shall be considered
24 disposal.
25 (8) The term “transport” means the movement of
147

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1 wastes from the point of generation to any intermediate
2 transfer points, and finaily to the point of ultimate dis-
3 posal.
4 (9) The term “treatment” means any activity or proc-
5 essing designed to change the physical form or chemical
6 composition of waste so as to render such materials non-
7 hazardous.
8 (10) The term “disposal of waste” means the dis-
9 charge, deposit, or injection into subsurface strata or exca-
10 vations or the ultimate disposition onto the land of any
11 waste.
12 (11) The term “disposal site” means the location where
13 any final deposition of waste materials occurs.
14 (12) The term “treatment facility” means a location
15 at which waste is subjected to treatment and may include
16 a facility where waste has been generated.
17 (13) The term “person” means any individual, partner-
18 ship,’ copartnership, finn, company, corporation, association,
19 joint stock company, trust, State, municipality, or any legal
20 representative agent or assigns.
21 (14) The term “municipality” means a city,. town,
borough, county, parish, district, or other public body created
by or pursuant to State law with responsibility for the plan-
ning or administration of waste management, or an Indian
i tribe or an authorized Indian tribal organization.
148

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1 (15) The term “was te management” means the sys-
2 tematic control of the generation, storage, transport, treat-
3 ment, recycling, recovery, or disposal of waste materials.
4 STANDARDS AND GTJIDELII ES FOR STATE REGULATION
5 SEC. 4. (a) Within eighteen months after the date of
6 enactment of this Act, and from t rne to time thereafter, the
7 Administrator pui uant to this section and after consultation
8 with representatives of appropriate Federal agencies shall by
9 regulation—
10 (1) identify hazardous wastes;
ii (2) establish standards for treatment and disposal
12 of such wastes; and
13 (3) establish guidelines for State programs for im-
14 plementing such standards.
15 (b) In identifying a waste as hazardous, pursuant to
16 this section, the Administrator shall specify quantity, con-
17 centration, and the physical, chemical, or biological proper-
18 ties of such waste, taking into account means of disposal,
19 disposal sites, and available disposal practices.
20 (c) The standards established under this section shall
21 include minimum standards of performance required to pro-
22 tect human health and other living organisms and minimum
23 acceptable criteria as to characteristics and conditions of dis-
24 posal sites and operating methods, techniques, and practices
25 of hazardous wastes disposal taking into account the nature
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1 of the hazardous waste to be disposed. Such standards shall
2 include but not be limited to requirements that any person
3 generating waste must (1) appropriately label all containers
4 used for onsite storage or for tran sport of hazardous
5 waste; (2) follow appropriate prOcedures for treating haz-
6 ardous waste onsite; (3) transport all hazar lous waste
7 intended for offsite disposal to a hazardous waste disposal
8 facility for which a permit has been issued. In establishing
9 such standards the Administrator shall take into account
10 the economic and social costs and benefits of achieving such
11 standards.
12 (d) The guidelines established under paragraph (a) (3)
13 of this section shall provide that—
14 (1) with respect to disposal sites for hazardous
15 wastes, the State program requires that any person
16 obtain from the State a permit to operate such site;
17 (2) such permits require compliance with the
18 minimum standards of performance acceptable site cr1-
19 teria set by the guidelines;
20 (3) the State have such regulatory and other au-
21 thorities as may be necessary to carry out the purpose
22 of this Act, including, but not limited to, the authority
23 to inspeet disposal sites and records, and to judicially
24 enforce compliance with the requirements of an ap-
25 proved program against any person.
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1 (e) Within eighteen months of the promulgation of
2 final regulations under this Act, each State shall submit to
3 the Administrator evidence, in such form as he shall re-
4 quire, that the State has established a State program which
5 meets the requirement of the guidelines of paragraph (a)
6 (3) of this section. If a State fails to submit such evidence,
7 in whole or in part, the Administrator shall publish notice
8 of such failure in the Federal iRegister and provide such
9 further notification, in such form as he considers appropriate,
10 to inform the public in such State of such failure.
11 FEDERAL REGULATION
12 SEC. 5. (a) Within eighteen months after the date of
13 enactment of this Act and from time to time thereafter, the
14 Administrator after consultation with representatives of
15 appropriate Federal agencies may with respect to those
16 hazardous wastes identified pursuant to subsection (a.) (1)
17 of section 4 determine in regulations those of such wastes
18 which because of their quantity or concentration, or because
19 of their chemical characteristics, could if allowed to be dis-
20 persed into the environment result in, or contribute to, the
21 loss of human life or substantial damage to human health
22 or to other living organisms.
23 (b) The Administrator may promulgate regulations
2. establishing Federal standards and procedures for the
25 treatment and disposal of such wastes. Such Federal stand-
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1 ards and procedures shall be designed to prevent damage
2 to human health or living organisms from exposure to such
3 wastes identified pursuant to subsection (a) and may
4 include—
(1) with respect to hazardous waste disposal
6 sites—
7 (A) minimum requirements a.s to the char-
8 acteristics and conditions of such sites,
9 (B) minimum standards of performance for
10 the operation and maintenance of such sites, and
11 (C) recommendations as to specific design and
12 construction criteria for sueh sites; and
13 (2) with respect to hazardous waste treatment
14 facilities—
15 (A) minimum standards of performance for
16 the operation and maintenance, and
17 (B) recommendations based on available tech-
18 nology as to appropriate methods, techniques, or
19 practices for the treatment of specific wastes.
20 (c) The Administrator may issue a permit for the
21 operation of a hazardous waste disposal site or treatment
22 facility if, after a review of the design, construction, and
23 proposed operation of such site or facility, he determines
that such operation will meet the requirements and standardS
25 promulgated pursuant to subsection (b)
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1 (d) WTithin eighteen months after the date of enactment
2 of this Act, the Administrator shall promulgate regulations
3 establishing requirements for generators of hazardous wastes
4 subject to regulation under this section to—
(1) maintain records indicating the quantities of
6 hazardous waste generated and the disposition thereof;
7 (2) package hazardous waste in such a manner so
8 as to protect human health and other living organisms,
and label such packaging so as to identify accurately
10 such wastes;
11 (3) treat or dispose of all hazardous waste at a
12 hazardous waste disposal site or treatment facility for
13 which a permit has been issued under this Act;
14 (4) handle and store all hazardous waste in such a
15 manner so as not to pose a threat to human health or
16 other living organisms;
17 (5) submit reports to the Administrator, at such
18 times as the Administrator deems necessary, setting
19 out—
20 (A) the quantities of hazardous waste subject
21 to Federal regulation under this subsection that he
22 has generated;
23 (B) the nature and quantity of any other waste
24 which he has generated which he has reason to be-
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1 lieve may have a substantial adverse effect on
2 human health and other living organisms; and
3 (C) the disposition of all waste included in
4 categories (A) and (B).
5 (e) The Administrator may prescribe regulations re-
6 quiring any person who stores, treats, disposes of, or other-
7 wise handles hazardous wastes subject to regulation under
8 this section to maintain such records with respect to their
9 operations as the Administrator determines are necessary
10 for the effective enforcement of this Act.
11 (f) The Administrator is authorized to enter into coop-
12 erative agreements with States to delegate to any State
13 which meets such minimum requirements as the Adrninistra-
14 toT may establish by regulation the authority to enforce this
15 section against any person.
16 FEDERAL ENFORCEMENT
17 SEc. 6. (a) Whenever on the basis of any information
18 the Administrator determines that any person is in violation
19 of requirements under section 5 or of any standard under
20 section 4 (a) (2) under this Act, the Administrator may
21 give notice to the violator of his failure to comply with such
22 requirements or may request the Attorney General to corn-
mence a civil action in the appropriate United States district
24 court for appropriate relief, including temporary or perina-
25 nent injunctive relief. If such violation extends beyond the
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1 thirtieth day after the Administrator’s notification, the Ad-
2 ministrator may issue an order requiring compliance within
3 a specified time period or the Adnii tis1rator may request
4 the Attorney General to eoninience a civil action iii the
5 United States district court in the district iii which the vio-
6 latioii occurred for appropriate relief, including a temporary
7 or permanent injunction Prrn ided, That, in the case of a
8 violation of any standard itiider section 4 (a) (2) where such
9 violation occurs in a State which has submitted the evidence
10 required under section 4 (e). the Administrator shall give
11 notice to the State in which such violation has occurred
12 thirty days prior to issuing an order or requesting the Attor-
13 ney General to commence a clvi ii action. If such violator fails
14 to take corrective action within the time specified in the
15 order, he shall be liable for a civil penalty of not more than
16 25,000 for each day of continued noncompliance. The
17 Administrator may suspend or revoke any permit issued to
18 the violator.
19 (h) Any order or any suspension or revocation of a
20 permit shall become final unless, no later thaii 30 days after
21 the order or notice of the suspension or revocation is served,
22 the person or persons named therein request a public hear-
23 ing. Upon such request the Administrator shall promptly
24 conduct a public bearing. In connection with any proceed-
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1 ing under this section the Administrator may issue subpenas
2 for the attendance and testimony of witnesses and the produc-
3 tion of relevant papers, books, and documents, and may
4 promulgate rules for discovery procedures.
5 (c) Any order issued under this section shall state with
6 reasonable specificity the nature of the violation and specify
7 a time for compliance and assess a penalty, if any, which the
8 Administrator determines is a reasonable period and penalty
g taking into account the seriousness of the violation and any
10 good faith efforts to comply with the applicable requirements.
ii (d) Any person who knowingly violates any require-
12 ment of this Act or commits any prohibited act shall, upon
13 conviction, be subject to a fine of not more than $25,00()
14 for each day of violation, or to imprisonment not to exceed
15 one year, or both.
16 RESEARCU, DEVELOPMENT, INVESTIGATIONS, TECIrNICAL
17 ASSISTANCE AND OTRER ACTIVITIES
18 SEC. 7. (a) The Administratoi sh il ] conduct, encour-
19 age, cooperate with, and render fln&ncial and other assist.
20 ance to appropriate public (whether Federal, State, inter-
21 state, or local) authorities, agencies, and institutions, private
22 agencies and institutions, and individuals in the conduct of,
23 and promote the coordination of, research, development, in-
24 vestigations, experiments, surveys, and studies relating to—
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1 (1) any adverse health and welfare effects on the
2 release into the environment of material present in
3 waste, and methods to eliminate such effects;
4 (2) the operation or financing of waste manage-
5 ment programs;
6 (3) the development and application of new and
7 improved methods of collecting and disposing of waste
8 and processing and recovering materials and energy
9 from wastes; and
10 (4) the reduction of waste generation arid t.he re-
11 covery of secondary materials and energy from solid,
12 liquid, and semisolid wastes.
13 (b) In carryii g out the provisions of the preceding
14 subsection, the Administrator is authorized to—
15 (1) collect and make available, through publica-
lb tion. and other appropriate means, the results of, and
17 other information pertaining to, such research and other
18 activities, including appropriate recommendations in
19 connection therewith;
20 (2) cooperate with public and private agencies,
21 institutions, and organizations, and with any industries
22 involved, in the preparation and the conduct of such re-
23 search and other activities; and
24 (3) make grants-in-aid to and contract with public
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1 or private agencies and institutions and individuals for
2 research, surveys, development, and public education.
3 Contracts may be entered into without regard to sections
4 3648 and 3709 of the Revised Statutes (31 U.S.C. 529;
5 41 U.S.C. 5).
6 (c) The Interstate Commerce Commission, the Federal
7 Maritime Commission, and the Office of Oil and Gas in the
8 Department of the Interior, in consultation with the Environ-
9 mental Protection Agency and with other Federal agencies
10 as appropriate, shall conduct within twelve months of the
11 date of enactment of this Act and submit to Congress, a
12 thorough and complete study of rate setting practices with
13 regard to the carriage of secondary materials by rail and
14 ocean carriers. Such study shall include a comparison of
15 such practices with rate setting practices with regard to
16 other materials and shall examine the extent to which, if at
17 all, there is discrimination against secondary materials.
18 INSPEOT TONS
19 SEc. 8. (a) For the purpose of developing or assisting
20 in the development of any regulation or enforcing the
21 provisions of this Act, any person who stores, treats, trans-
22 ports, disposes of, or otherwise handles hazardous wastes
23 shall, upon request of any officer or employee of the Environ-
24 mental Protection Agency or of any State or political sub-
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1 division, duly designated by the Administrator, furnish or
2 permit such person at all reasonable times to have access to,
3 and to copy all records relating to such wastes.
4 (h) For the purposes of developing or assisting in the
5 development of any regulation or enforcing the provisions
6 f this Act, officers or employees duly designated by the
7 \. dini ni strator are authorized—
8 (1) to enter at reasonable times any establish-
9 rnent 01. other place maintained by any person where
10 hazardous wastes are stored, treated, or disposed of;
11 (2) to inspect and obtain samples from any person
12 of any such wastes and samples of any containers or
13 labeling for such wastes. Before undertaking such in-
14 spection, the officers or employees must present to the
15 owner, operator, or agent in charge of the establishment
16 or other place where hazardous wastes are stored,
17 treated, or disposed of appropriate credentials and a
18 written statement as to the reason for the inspection.
19 Each such inspection shall be commenced and completed
20 with reasonable promptness. If the officer or employee
21 obtains any samples, prior to leaving the premises, he
22 shall give to the owner, operator, or agent in charge
23 a. receipt describing the sample obtained and if requested
24 a portion of each such sample equal in volume or weight
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1 to the portion retained. If an analysis is made of such
2 samples, a copy of the results of such analysis shall he
3 furnished promptly to the owner, operator, or agent
4 in charge.
5 (c) Any records, reports, or information obtained from
6 any person under this subsection shall be available to the
7 public, except that upon a showing satisfactory to the Ad-
8 ministrator by any person that records, reports, or informa-
9 tion, or particular part thereof, to which the Administrator
10 has access under this section if made public, would divulge
11 information entitled to protection under section 1905 of
12 title 18 of the United States Code, the Administrator shall
13 consider such information or particular portion thereof eon-
fidential in accordance within the purposes of that section.
15 ENCOURAGEMENT OF INTERSTATE AND INTERLOCAL
16 COOPERATION
17 See. 9. The Administrator shall encourage cooperative
18 activities by the States and local governments in connection
19 with waste disposal programs, encourage, where practicable,
interstate, interlocal, and regional planning for, and the
21 conduct of, interstate, interlocal, and regional hazardous
22 waste disposal programs; and encourage the enactment of
23 improved and, so far as practicable, uniform State and local
24 laws governing waste disposal.
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1 IMMINENT HAZARD
2 SEc. 10. (a) An imminent hazard shall be considered to
3 exist when the Administrator has reason to believe that
4 handling or storage of a hazardous waste presents an im-
5 minent and substantial danger to human health or other liv-
6 ing organisms the continued operation of a disposal site will
7 result in such danger when a State or local authority has
8 not acted to eliminate such risk.
9 (h) If an imminent hazard exists, the Administrator
10 may request the Attorney General to petition the district
11 court of the United States in the district where such hazard
12 exists, to order any disposal site operator or other person
13 having custody of such waste to take such action as is neces-
14 sary to eliminate the imminent hazard, including, but not
15 limited to, permanent or temporary cessation of operation of
16 a disposal site, or such other remedial measures as the court
17 deems appropriate.
18 PROELBITED ACTS
19 SEc. 11. The following acts and the causing thereof are
20 prohibited and shall be subject to enforcement in accord-
21 ance with the provisions o subsection 6 (d) of this Act:
22 (a) Operating any disposal site for hazardous waste
23 identified pursuant to section 5 without having obtained an
24 operating permit pursuant to such section.
25 (b) Disposing of hazardous waste identified pursuant
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1 to section 5 in a manner not in compliance with requirements
2 Under section 5.
3 (c) Failure to comply with the requirements of section 5
4 in labeling containers used for the storage, transport, or dis-
posal of hazardous waste.
6 (d) Failure to comply with (1) the conditions of any
7 Federal permit issued under this Act, (2) any regulation
8 promulgated by the Administrator pursuant to section 4 (a)
(2) or section 5 of this Act, or (3) any order issued by the
10 Administrator pursuant to this Act.
11 APPLICATION OF STANDARDS TO FEDERATI AGENCIES
12 SEc. 12. (a) Each department, agency, and instruinen-
13 tality of the executive, legislative, and judicial branches of
14 the Federal Government having jurisdiction over any prop-
15 erty or facility, or engaged in any activity which generates,
16 OT which may generate, wastes shall insure compliance with
17 such standards pursuant to subsections 4(a) (2), 5 (a), and
18 5(c) as may be established by the Administrator for the
19 treatment and disposal of such wastes.
(b) The President or his designee may exempt any
21 facility or activity of any department, agency, or instruxnen-
ta]ity in the executive branch from compliance with guide-
lines established under section 4 if he determines it to be in
the paramount interest of the United States to do so. Any
exemption sb,ill be for a period not in excess of one year,
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1 but additional exemptions may be granted for periods of not
2 to exceed one year upon the President’s or his designee’s
3 making of a new determination. The Administrator shall
4 ascertain the exemptions granted under this subsection and
5 shall report each January to the Congress all exemptions
6 from the requirements of this section granted during the pre-
7 ceding calendar year.
8 (c) Within eighteen months after enactment of this Act
9 and from time to time thereafter, the Administrator, in con-
10 sultation with other appropriate Federal agencies, shall
11 identify products which can utilize significant quantities of
12 secondary materials and shall issue guidelines with respect
13 to the inclusion of such secondary materials to the maximum
14 extent practicable in products procured by the Federal
15 Government.
16 (d) In any proceeding initiated before the Interstate
17 Commerce Commission or the Federal Maritime Commis-
18 sion after the enactment of this Act where a determination
19 is made by such Oommis ion as to any individual or joint
20 rate, fare, or charge whatsoever demanded, charged, or
21 collected by any common carrier or carriers, a specific find-
22 ing by the Commission will be required that such rate, fare,
23 or charge does not or will not cause discrimination against
seeondary materials.
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1 CITIZEN SUITS
2 SEC. 13. (a) Except as provided in subsection (b) any
3 person may commence a civil action for injunctive relief on
4 his own behalf—
5 (1) against any person who is alleged to be in
6 violation of any regulation promulgated or order issued
7 under this Act;
8 (2) against the Administrator where there is al-
9 leged a failure of the Administrator to perform any act
10 or duty under this Act which is not discretionary with
11 the Administrator.
12 Any action under paragraph (a) (1) of this subsection
13 shall be brought in the district court for the district in which
the alleged violation occurred and any action brought under
15 paragraph (a) (2) of this subsection shall he brought in
16 the District Court of the District of Columbia. The district
courts shall have jurisdicdon, without regard to the amount
18 in controversy or the citizenship of the parties, to enforce
19 such regulation or order, or to order the Administrator to
° perform such act or duty as the case may be.
21 (b) No action may be commence&—
(1) under subsection (a) (1) of this section—
(A) prior to sixty days after the plaintifi has
given notice of the violation (1) to the Adminis-
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1 trator, (II) to the State in which the alleged viola-
2 tion occurs, and (iii) to any alleged violator of the
standard, limitation, or order, or
4 (B) if the Administrator or State has caused to
3 be commenced and is diligently prosecuting a civil
6 or criminal action in a court of the United. States
7 or a State to require compliance with requirements
8 of this Act or order issued hereunder;
9 (2) under subsection (a) (2) prior to sixty days
10 after plaintiff has given notice of such action to the
11 Adiiiini trator.
12 Notice under this subsection shall be given in
13 such manner as the Administrator shall prescribe by
14 regulation.
15 (3) in such action under this section, lithe United
16 States is not a party, the Attorney Genera’ may inter-
17 vene as a matter of right.
18 (d) The court, in issuing any final order in any action
19 brought pursuant to this section, may award costs of lifiga-
20 tion (including reasonable attorney and expert witness fees)
21 to any party, whenever the court determines such award is
22 appropriate.
23 (e) Nothing in this section shall restrict any right
24 which any person (or class of persons) may have under any
25 statute or common law to seek enforcement of any regulation
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1 or to seek any other relief (including relief against the Ad-
2 ministrator or a State agency).
3 STATE AUTHORITY
4 SEc. 14. (a) If the Administrator has promulgated
5 regulations under section 5 no State or municipality may
6 without the approval of the Administrator impose more
7 stringent requirements than those imposed under the pro-
8 visions of section 5 on the transport, treatment, or disposal
9 of hazardous wastes.
10 (b) No State or municipality shall impose, on wastes
11 originating in other States or municipalities, requirements re-
12 specting the transport of such wastes into or disposal within
13 its jurisdiction which are more stringent than those require-
14 merits applicable to wastes originating within such receiving
15 States and municipalities.
16 AUTHORIZATION AND APPROPRIATION
17 Si c. 15. There is hereby authorized to be appropriated
18 to the Environmental Protection Agency such sums as may
19 be necessary for the purposes and administration of this Act.
20 JUDICIAL REVIEW
21 SEC. 16. (a) A petition for review of action of the Ad-
22 ministrator in promulgating any regulation pursuant to see-
tions 4 or 5 shall be filed in the United States Court of Ap-
pe*.h for the District of Columbia. Any person who will be
adve *e1y affected by & final order or other final determina-
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1 tion issued under section 6 may file a petition with the
2 United States Court of Appeals for the circuit wherein such
3 person resides or has his principal place of business, for a
4 judicial review of such order or determination. Any such
5 petition shall be ified within thirty days from the date of such
6 action or order, or after such date if such petition is based
7 solely on grounds arising after such thirtieth day.
8 (b) Action of the Administrator with respect to which
9 review could have been obtained under subsection (a) shall
10 not be subject to judicial review in civil or criminal proceed-
11 ings for enforcement.
12 (c) In any judicial proceeding in which review is
13 sought of an action under this Act required to be made on
14 the record after notice and opportunity for hearing, if any
15 party applies to the court for leave to adduce additional
16 evidence, and shows to the satisfaction of the court that such
17 additional evidence is material and that there were reason-
18 able grounds for the failure to adduce such evidence in the
19 proceedings before the Administrator, the court may order
20 such additional evidence (and evidence in rebuttal thereof)
21 to be taken before the Administrator, in such manner and
22 upon such terms and conditions as the court may deem
23 proper. The Administrator may modify his findings as to
24 the 1& ts, or make new findings, by reason of the additional
25 evidence so taken and be shall file such modified or new
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1 findings, and his recommendation, if any, for the modifica-
2 tion or setting aside of his original determination, with the
3 returii of such additional evidence.
4 RELATIONSHIP TO OTHER LAWS
5 S c. 17. (a) ThisAct shall notapplyto—
6 (1) any source material, special nuclear material,
7 or byproduct material subject to regulation or control
8 pursuant to the Atomic Energy Act of 1954, as
9 amended;
10 (2) lethal chemicals subject to regulation pur-
11 suant to title 50, Fnited States Code, section 1511,
12 and the following, as amended.
13 (b) This Act shall not be construed to relieve any
14 person from any present or future requirement arising from
15 any other Federal law.
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